IN THE CIRCUIT COURT OF THE

SIXTH JUDICIAL CIRCUIT

IN AND FOR TUSCALOOSA COUNTY, ALABAMA

 

STATE OF ALABAMA             )

                             )

VS.                          )     CC92-1893

                             )

BETTY WOODS WILSON,          )

                             )    

Defendant.         )

 

* * * * * * * * *

VOLUME I

 

Preliminary Proceedings and

Juror Selection. . . . . . . . . . . . Pg 2 to 193

 

Opening Statement – Jimmy Fry,

State’s Prosecutor. . . . . . . . . . .Pg 194 to 218

 

Opening Statement – Bobbie Lee Cook,

one of Wilson’s defense lawyers. . . . Pg 219 to 231

 

Direct Examination by Mr. Fry –

Jimmy Dunnagan, Police Officer HPD. . . Pg 236

 

Cross Examination by Mr. Hooper –

Jimmy Dunnagan, Police Office HPD . . . Pg 251

 

Direct Examination by Mr. Fry –

Glen Nunley, Investigator HPD. . . . . .Pg 261

 

Cross Examination by Mr. Hooper –

Glen Nunley Investigator HPD. . . . . . Pg 328

 

 

 

 

 

 

 

 

 

 

 

 

Page 1


 

IN THE CIRCUIT COURT OF THE

TWENTY-THIRD JUDICIAL CIRCUIT

IN AND FOR MADISON COUNTY, ALABAMA

 

STATE OF ALABAMA,        )

                         )

VS.                      )         CC92-1194FY

)         CC92-1893

BETTY WOODS WILSON,      )         (Tuscaloosa County)

)

Defendant.     )

 

* * * * * * * * * *

 

C A P T I 0 N

The above-entitled cause came on to be

heard before the Honorable Thomas N. Younger,

Judge, on the 9th day of July, 1992, commencing at

2:05 p.m., Madison County Courthouse, Huntsville,

Alabama, when the following proceedings were had

and done:

A P P E A R A N C E S

For the State:           Hon. Mo Brooks

Hon. Susan Moquin

 

 

For the Defendant:       Hon Charles Hooper

Hon Marc Sandlin

Hon. Doug Martinson, II

 

* * * * * * * * * * *

 

A.D. HARRISON

Official Court Reporter

Huntsville, Alabama

(205) 532-3444

 

 

 

Page 2


P R 0 C E E D I N G S

THE COURT:  This is a hearing on a motion

filed by the State in the matter of State vs. Betty

Woods Wilson.

Is the State ready?

MS. MOQUIN: Yes, sir.

THE COURT:  Is the defendant ready?

MR. HOOPER:  Yes, sir, Judge.  Have you

got -- we had filed a motion, an objection.

THE COURT:  I only have a motion --I only

have the State's motion.

MR. HOOPER: Okay. Let me give you my

copy.

MS. MOQUIN: Charlie, we don't have a

copy of that.

MR. HOOPER:  It was delivered to your

office.

Judge, generally we would have 14 days to

reply and, of course, since we not it late

yesterday --

THE COURT: Well, you have a motion to --

an objection to a subpoena duces tecum, and I'm not

aware of a subpoena duces tecum.  We are on the

motion for discovery, or in the alternative, motion

 

Page 3


to compel, which is -- which was filed by the State,

I believe, yesterday.

MR. SANDLIN:  Judge, there was a subpoena

attached to the motion.

MS. MOQUIN:  I don't believe so.

MR. SANDLIN:  That's what that's about.

MS. MOQUIN: Judge, if any subpoenas have

been delivered, they have been delivered

independent of this motion.   This motion stands on

its own.

THE COURT:  I'm not aware of one.

MR. HOOPER:  Delivered by Bruno Procopio.

I assume you all know about it.

MS. MOQUIN: We certainly know about it.

THE COURT: Let me have the motion.

MR. SANDLIN:  Set today.

THE COURT: This is the only one I have.

MR. HOOPER:  Judge, our objection

certainly goes to that.

THE COURT:  Do what?

MR. HOOPER:  Our objection goes to that,

the motion which they have filed.

THE COURT: Well, I'm going to hear it.

I'm going to hear the motion, and I'll listen to

 

Page 4


both sides.

MR. HOOPER: Yes, sir.

THE COURT:  So you may present whatever

you would like to going to your objection and going

to the motion by the State.

MR. HOOPER: Yes, sir.

THE COURT:  You may proceed.

MS. MOQUIN:  Your Honor, to begin with, I

would like to cite to the Court and present to the

Court three cases upon which we base our opinion

that we are entitled to pieces of physical evidence

that the defense may have in its possession or

control.

And I cite to you first, Your Honor, the

State -- Fisher vs. the United States, which is

located at 425 US 391, 46 L Ed 2d 39, 96 S Ct 1569,

which stands for the proposition that pieces of

documentary evidence are entitled to be discovered

by the State and are not privileged information,

nor are they a violation of a defendant's privilege

against self-incrimination.

Your Honor, we would cite to you further

two Alabama cases.

Cotton vs. State. That is Volume 6 of

 

Page 5


the Southern Reporter, page 396, wherein our Court

stated that "Between an attorney and a client --"

THE COURT:   Give me the year.

MS. MOQUIN: It's an 1889 case, Your

Honor.

THE COURT:   Well, I thought it went back

to --

MS. MOQUIN: Yes, sir, because of the

volume.

Your Honor, to my knowledge, it's never

been overturned.

THE COURT: Go ahead.

MS. MOQUIN:   States for the Proposition,

and I'll read to the Court with regard to the

opinion.   "As between attorney and client, only to

communications made and received for the purposes

of professional action and aid," are entitled to

have the privilege extended to them. "Any

conferences in the presence and hearing of third

persons, whether they be officers of the law."

This case allows for the State to discover that

type of information.

Your Honor, I cite to you further, State

vs. Joy.   This is a Louisiana case, 94 Southern

 

Page 6


Reporter, 910., wherein, Your Honor, in this case

two pieces of physical evidence were allowed in in

this case and held as competent evidence and was

not considered to be privileged communications.

Your Honor, I have numerous other cases

from other jurisdictions. I was holding the

information to my oral argument to cases near or in

this jurisdiction or U.S. Supreme Court cases.

Based on these cases, we have filed our motion. We

are requesting that we be entitled to, as we have

set out in our motion, the list on Page 2 of the

motion, the items that we designated there.  Each

of these items, Your Honor, are pieces of physical

evidence. Based on that, Your Honor, Item 4, we

have requested any items obtained, received, taken

directly or indirectly from the home of Peggy Woods

Lowe since May 22, 1992.

In the investigation by the police

department, they determined that Jerry McDaniel

arrived at the home of Peggy Woods Lowe prior to

their arrival, and that he possibly removed

physical items from that location.

Your Honor, in that regard we have

subpoenaed him here today to ask him on the stand if

 

Page 7


he did in fact take into his custody any physical

items    And, Your Honor, we would call him to the

stand at this time to ask him that question.

MR. HOOPER:   Judge, I'm going to, of

course, object to that under Rule 16.4b. He was

employed by us.    To the -- Ms. Moquin's statement

that he arrived before the police, I wouldn't mind

him testifying to that.     He was not employed until

some, what, two weeks after Jack Wilson's death.

The police held this house for two weeks, at which

time they gave the house back over to us.      And

certainly we had an opportunity to go in the house,

but that's an outright misstatement of the facts.

THE COURT: And you say that you don't

object to his testifying to what?

MR. HOOPER: Only to this: We will

submit to you that our investigator did not have

access to that house until it was released by the

police.   Ms. Moquin's comment was to the fact that

our investigator arrived before the police.       So I

assume that she is saying our investigator arrived

the night of the murder.    That's an out -- that's

stupid.

MS. MOQUIN: Your Honor, we are talking

 

Page 8


about the home of Peggy Lowe, not the home of Betty

Wilson.

MR. HOOPER:   Okay.  Peggy Lowe?

MS. MOQUIN:   Right.

MR. HOOPER:   All right.  Judge, our

investigator has been to several places.     I would

object to it.

MS. MOQUIN:   Your Honor, I do have a case

cite with regard to this specific request.     This is

a California case, Your Honor.    The name of the case

is People vs. Meredith, 631 Pacific Reporter, 2d.

THE COURT:   Give me that again.   631?

MS. MOQUIN: Yes, sir.

THE COURT: Pacific?

MS. MOQUIN: Reporter, 2d, page No. 46.

And I direct Your Honor --

THE COURT: Page No. 46?

MS. MOQUIN:   Yes, sir.  I'm sorry, Judge,

I'm going too fast.

THE COURT: Okay.

MS. MOQUIN:   I direct your attention,

Your Honor, to headnote No. 9 there, and I'll just

- if I may have your permission, just read that.

"Even though communication from murder suspect to

 

Page 9


his attorney that suspect had burned victim's

wallet and placed it in a trash can was privileged,

confidential communication, once counsel chose to

send investigator to retrieve wallet from the trash

can, original location and condition of evidence

lost protection of privilege, and, therefore, trial

court did not err, in murder prosecution, in

admitting investigator's testimony concerning

location of the wallet."

Based on that, Your Honor, we believe

that we are entitled to ask him if he retrieved any

physical items from that location.

THE COURT: Well, the Court, in its

ruling, will address that issue.

MS. MOQUIN: All right, sir, Your Honor.

Your Honor, further, and just for the record, we

would state that this is the home of Peggy Woods

Lowe, and neither one of these attorneys, at the

current time, represent Peggy Woods Lowe. And,

therefore, we would assert that their attorney-

client privilege does not extend to her home or her

possessions.

MR. HOOPER:  Judge, that's great.  Let

her call Peggy Lowe, then, not my investigator.

 

Page 10


THE COURT:  Okay.  Anything further?

MS. MOQUIN:  Your Honor, we, of course,

based on the arguments that we have previously

presented, we believe that we are entitled to the

list of items on the second page of our motion, I

through 5.

Your Honor, if I might speak to paragraph

5 there. Your Honor, we are asserting that we would

-- we need copies of any and all records that

concern the estate of Dr. Jack Wilson and/or Betty

Wilson, including wills, codicils, and records that

might be in the possession of Mr. Hooper or his law

partners.  Your Honor, we would assert that there

is no attorney-client privilege with regard to

records prepared for and at the request of Dr. Jack

Wilson, such as his will, any wills prepared by him

or an attorney for him, and that they cannot assert

unless they were acting as attorneys for Dr. Jack

Wilson in that regard; there is no attorney-client

privilege with regard to that information.

Your Honor, again, with regard to our

motion, we have asked for any other documentation,

physical items that the defense intends to produce

at the time of trial.  And, Your Honor, that is in

 

Page 11


accordance with Rule 16.2, that we are entitled to

have an opportunity to review all of those things

before trial.

THE COURT:  Is that it?

MS. MOQUIN,  Yes, sir.

THE COURT: Mr. Hooper?

MR. HOOPER: Judge, obviously we would

like to have an opportunity to respond.  I don't

believe that the notice that was provided for us,

and the Court could expect us to really reply to the

cases --

THE COURT:  You don't believe what?

MR. HOOPER: That the Court could expect

us to be able to reply to these cases she cited. I

know offhand Fisher vs. State involved tax

prosecutions and some tax records.  We would like

to have an opportunity to review those cases and

respond.

We do believe that what she has asked for

are provided under the rules of discovery,

specifically Rule 16.2, with respect to physical

items that can be recovered from the defendant.  We

would ascertain that -- we would submit that Mrs.

Woods does still have some constitutional rights,

 

Page 12


one of which is to have counsel and also have some

preparation for trial.

We were glad to be enlightened by the

State that apparently, by their argument, that we

are going to have access to all the persons they

have talked to and a summary of all the statements

they have taken.  I assume it would go both ways.

But we would like to have an opportunity to respond

to what they have asserted.

They are basically asking us if we have

got an investigator, to turn it all over to them.

THE COURT: How do you want to respond,

with a memorandum?

MR. HOOPER:  Yes, sir, just a memorandum,

but we certainly believe that their motions, we

submit to you, would be due to be denied.

THE COURT: Anything else at this time?

MR. SANDLIN: Judge, the only other thing

I could add, I know you are aware of this rule 16.2

of the Rules of Criminal Procedure, relating to

discovery by the State.  It's clear in there that

you have got 14 days, even if you grant their

motion, to respond to that stuff. Some of the items

that they have requested in their motion here,

 

Page 13


specifically the clothes and shoes -- some of the

items that they have requested in their motion has

been submitted to an agency of the State of

Alabama, the Department of Forensic Sciences, that

is under the auspices of the State of Alabama, and

they have that.

MR. HOOPER: Judge, in response to that,

those items have been submitted to the State, as

conferences with that agency some weeks ago, to

perform certain tests.  And it's my understanding

that if they want some tests performed on items

that we have submitted, then they are free to do

that.  You know, we believe this to be physical

evidence. We certainly don't want the State to

have it, something may happen to it.  It might be

contaminated by their deeds.  So we think it's

important to us and we want to safeguard it.

THE COURT:  Okay.  Anything further?

MR. SANDLIN: No, sir.

THE COURT: Anything further?

MS. MOQUIN:  Your Honor, if I might

respond with regard to the items that have already

been delivered to the Department of Forensic

Sciences.  As far as those actual items are

 

Page 14


concerned, we are not aware as to whether or not

they are the full number of items that were

delivered to Mr. Hooper's office by Mr. Cagle on or

about the 27th or 28th.  There could have been other

items.

Also, Your Honor, we would like to have

the opportunity to have physical control of those

items for a period of time, to allow witnesses that

we have talked to to see those items and perhaps

give us an acknowledgement that she was or was not

wearing those items on that occasion.

Further, Your Honor, I think that this

Court has an inherent ability, outside of the rules

of discovery, to make these orders.  But if, per

chance, items have come into the control and

possession of the defense and are no longer in

their possession or control and have been given to

other persons or located in another area, Your

Honor, we would like to know what those items were,

because they are not available for us in their

original location.

MR. SANDLIN: [or Hooper] What's that all about?

MS. MOQUIN: Mr. Hooper, I will be happy

to explain that.

Page 15


MR. HOOPER:  I sure wish you would.

MS. MOQUIN:  If someone has produced

something at your request and delivered it to your

office, and you had an opportunity to look at it,

then it's not in the same location as where one of

the defendants might have last placed it. And you

may have looked at it and done something with it and

given it to -- back to the person who delivered it

and now it's not in its original location where

it's available to us to find.

MR. HOOPER:  And you want me to fill in

all the blanks for you; right? That's a fishing

expedition.

Ms. MOQUIN. Charlie, if you want to put

words in my mouth, that's up to you.

MR. HOOPER: That's a good one.

THE COURT: Anything further?

MS. MOQUIN: No, sir.

THE COURT: Anything further?

MR. HOOPER:  No, sir.

THE COURT: Then, the Court will take

under advisement your motion and will render a

decision.

Before we conclude this hearing, however,

 

Page 16


I would like to admonish all that are involved in

this case, the parties, the attorneys for both

sides, and the various news media, that this case

should be tried in the courts and not in the media.

With this view in mind, all of our

efforts should be directed to secure and maintain

and safeguard the rights of the individual accused,

to a fair and impartial trial , and on the other hand

to secure efforts by the media to safeguard the

rights of the public to know what's happening in

the court system.

In balancing First Amendment rights of

freedom of the press and the Sixth Amendment rights

to a fair and impartial trial, we, indeed,

sometimes walk a fine line.

This Court recognizes that the news media

has a right and responsibility to disseminate the

truth; that parties to litigation have the right to

a fair and impartial trial; that the public is

entitled to be informed; that editors and news

directors have the right to make news judgments,

but should do so with accuracy and with

objectivity, keeping in mind that the accused is

presumed innocent until proven guilty; that

 

Page 17


readers, listeners, and viewers are potential

jurors, and as such may be influenced by what they

see, hear, and read.

The Court also recognizes that it bears

the final responsibility for maintaining order and

ensuring justice for all litigants in the judicial

process. This applies both legally and ethically,

and in fact Cannon 3 of the Cannons of Judicial

Ethics provides, and I quote, "A Judge should

abstain from public comment about a pending o@

impending proceeding in any court, and should

require similar abstention on the part of court

personnel subject to his direction and control."

This Court is concerned, at this point,

that if the current dialogue continues, it will be

impossible to afford the accused in this community

a fair and impartial trial.

With this in mind, I want to admonish all

concerned, the attorneys on both sides and the

various news media, to exercise restraint in all

matters relating to the trial of these cases, in

order that justice may be served.

Now, copies of my remarks are available

to any of you that would like to have them. If you

 

Page 18


will see my secretary, they are available to anyone

who would like to have a copy.

And with that, ladies and gentlemen,

court is in recess. Thank you.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Page 19


 

 

IN THE CIRCUIT COURT OF THE

SIXTH JUDICIAL CIRCUIT

IN AND FOR TUSCALOOSA COUNTY, ALABAMA

 

STATE OF ALABAMA             )

                             )

VS.                          )     CC92-1893

                             )

BETTY WOODS WILSON,          )

                             )    

Defendant.         )

 

* * * * * * * * *

 

C A P T I 0 N

 

The above-entitled cause came on to be

heard before the Honorable Thomas N. Younger,

Judge, on the 18th day of February, 1993,

commencing at 9 :0 3 a.m. , Madison County Courthouse,

Huntsville, Alabama, when the following proceedings

were had and done:

 

 

A P P E A R A N C E S

 

For the State:          Hon. Jimmy Fry

 

Hon. Kristi Adcock

 

For the Defendant:      Hon. Bobby Lee Cook

Hon. Charles Hooper

Hon. Marc Sandlin

Hon. Jack Drake

 

 

 

 

Page 20


P R 0 C E E D I N G S

THE COURT:   Mr. Hooper, Mr. Sandlin, are

you gentlemen ready?

MR.  HOOPER: Yes, sir.

THE  COURT: Mr. Fry?

MR.  FRY:  State is ready, Your Honor.

THE  COURT:   Would you gentlemen like to

introduce  your co-counsel?

MR.  HOOPER: Yes, sir.

THE  COURT: To the Court?

MR.  HOOPER: Judge, this is Bobby Cook

from Georgia.

MR. COOK:   Good morning, Your Honor.      I'm glad to be here.

THE COURT: Nice to see you, nice to have

you with us.

MR. HOOPER: Judge, you may know Jack Drake.

MR. DRAKE:    Judge, how are you?    I don't

think we have actually met.

THE COURT:    Not personally, but I believe

I have seen you and know of you.

MR. DRAKE: [THE COURT?]   I know two of your brothers , anyway.

 

 

Page 21


THE COURT:  They are no doubt younger

brothers.  All right.   Now, I believe that the

defendant has been arraigned.

MR. HOOPER:  That's correct.

THE COURT:  And you gentlemen have not

filed a written plea on her behalf?

MR. SANDLIN:  That's correct.

MR. HOOPER:  That is correct.

THE COURT:  We discussed this at the last

meeting.  I don't believe that it's a

jurisdictional matter, but for the record, do you

both agree that the arraignment can take place

here?

MR. HOOPER:  Judge, we had preferred that

the arraignment took place in Tuscaloosa before the

jury, that was our preference.

THE COURT: Well, before the jury would

be -- she could be re-arraigned, if necessary.

MR. HOOPER: Yes, sir, we would like to

do that, and other than that it will be fine.

THE COURT:  All right. Mrs. Wilson, if

you will, come around, please, ma'am. Mr. Fry, do

you have the indictment?

MR. FRY:  Your Honor, I guess that would

 

Page 22


[PAGE 23 MISSING]

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Page 23

Alabama 1975, 13A-5-40(a) (7), against the peace and

dignity of the State of Alabama.

That's Count No.I, Your Honor.

THE COURT:  Mrs. Wilson, you heard the

reading of Count 1 of the indictment charging you

with the offense of capital murder. To Count I of

the indictment charging capital murder, how do you

plead?

THE DEFENDANT:  I plead not guilty, Your

Honor.

THE COURT: Read Count 2.

MR. FRY:  "Count 2:  The grand jury of

said county charge, that before the finding of this

indictment, Betty Woods Wilson, whose name is

unknown to the grand jury other than as stated, did

intentionally cause the death of Dr. Jack W.

Wilson, for hire, to-wit:   Betty Woods Wilson hired

James Dennison White to kill Dr. Jack W. Wilson, by

paying James Dennison White, to-wit: $2,500 in

United States currency, and promising to pay James

Dennison White more money, to-wit: an additional

$2,500 in United States currency, and James

Dennison White did kill Dr. Jack W. Wilson, by

beating him with a baseball bat or other blunt

 

Page 24


instrument, or stabbing him with a knife or other

sharp instrument, in violation of Code of Alabama

1975, 13A-5-40(a)(7), against the peace and dignity

of the State of Alabama."

THE COURT: Mrs. Wilson, you heard the

reading of Count 2 of the indictment charging

capital murder.  To Count 2 of the indictment, how

do you plead?

THE DEFENDANT: I'm not guilty.

THE COURT: All right.  You plead not

guilty, and the case is set for trial, set to begin

for trial on February 22nd.  The case having been

transferred previously by this Court to Tuscaloosa

County, will proceed and begin in the Circuit Court

of Tuscaloosa County on the morning of February the

22nd.

You may be seated.

(Brief pause.)

THE COURT: Now,gentlemen, it was

agreed, and by order of this Court previously

entered, motions pending -- outstanding motions

that are pending at this time were agreed to be

heard. What motions do you have, gentlemen, that

you would like to be heard on at this time?

 

Page 25


MR. DRAKE: Judge, it may be best to

start with what I think is the easiest.  If the

press reports are correct, Mr. Fry has agreed that

we can use a juror questionnaire.  And if he does

agree to that, then that's one of our notions, to

ask the Court to allow us to do that and suggest a

procedure for doing it.

THE COURT: Mr. Fry, what's the position

of the State?

MR. FRY: Your Honor, I have no  -- don't

want to invade the province of the Court. As far as

I'm concerned, the questions, with exception of the

last, which asks about whether or not the jurors

think the defendant is probably guilty, with

exception of that last question, I feel like they

are probably questions that the defense could ask

on an oral voir dire before the jury.  So I'm not

suggesting to the Court that that's the way to go,

but I don't have any problems with the form being

used.  And, in fact, I think it probably would be

time saving and probably a very efficient way of

helping with voir dire in this case.  I do object to

the last question.  I don't think there is enough

predicate laid for that to be a good question for

 

Page 26


the jury to have.

MR. DRAKE: Well, Judge, may I speak to

that, just to the issue of the last question?

THE COURT: Well, let's clear up the

other, first.  First of all would be the use of the

questionnaire.  I don't have any problem with that.

The problem is -- you know the courthouse in

Tuscaloosa because that's your circuit. The venire

room or assembly room probably does not have any

tables or anything.  And I note from the motion

there is about an eight-page questionnaire.  How in

the world will the jury be able to fill them out?

Secondly, once filled out, both sides will need a

copy of them.  How are you going to get copies?

MR. DRAKE: I have talked with the

Circuit Clerk about this a couple of weeks ago, and

a questionnaire has been used at least once in our

circuit.  And, of course, they have been used

frequently in Jefferson County.

Our jury comes in, they look at a 15-

minute instructional film, and they are given

instructions, and so forth, pretty much the way it

is in most places.  I propose that we distribute the

questionnaire to people at that time, provide them

 

Page 27


with a pen to fill out the questionnaire, and give

them 30 minutes or so, however long it would take to

do it.  I would then undertake --

THE COURT: Where would they do it?

MR. DRAKE:  In the jury assembly room.

THE COURT:  Are there tables?

MR. DRAKE:  There are some tables.   There

may not be enough tables --

THE COURT:  I don't know how a juror will

hold a piece of paper on his lap and fill it out.

That's the problem that I see with it.

MR. DRAKE: Well, a great many of the

questions just call for a checking of a box, you

know.  If you don't answer "Yes" in some instances

or "No" in some instances, there is no need to

provide

THE COURT:  You think that presents no

problem?

MR. DRAKE: I don't think so. And the

Circuit Clerk, I asked her and she didn't seem to be

troubled about it.   We will undertake to provide

copies to Mr. Fry and we will provide all the

material.   So, you know, nobody gets cost anything,

like in the post office, and I'll immediately start

 

Page 28


working with them to handle the mechanics of it.

THE COURT: Well, I have no problem with

the use of the questionnaire itself. Now, the last

question, if you want to address yourself to that.

MR. DRAKE:  Yes. On voir dire to the

entire venire, we can ask that question. I mean,

obviously --

THE COURT:  Certainly a relevant question

that you might ask. There might be some predicate

laid, some more information given to the 3'ury

before that question.

MR. DRAKE: Well, we do in the

questionnaire.  We tell them basically the

essential facts of what has happened. And, of

course, there has been an enormous amount of

publicity about this case, as you know. And one of

the things that I have undertaken to do, and it's

strictly informal and anecdotal, is ask people what

they have heard about the case, and everybody in

Tuscaloosa has heard about it, as far as I know.

So, based on what they have heard, I want to know if

they have formed an opinion, and it seems to me we

would be entitled to ask that.

THE COURT: Mr. Fry, have you seen the

 

Page 29


questionnaire?

MR. FRY: Yes, sir.

THE COURT:  I haven't seen it, because it

was filed in Tuscaloosa and -- I have a copy of it,

it came in about two minutes before I came in the --

about five minutes before I came in the courtroom.

I have not had time to read it.

MR. DRAKE:  May I read you the question

he is talking about?  It's No. 54. Says, "Do you

think, based on what you have read or heard, that

Betty Woods Wilson is probably guilty as charged?"

Yes or no.

THE COURT: Mr. Fry, I don't see anything

wrong with the question.

MR. FRY: okay, Your Honor.

THE COURT: So the questionnaire will be

permitted.  And you will undertake, as I understand

it, to --

MR. DRAKE:  Yes  sir.  And if you think of

any special instructions or questions or whatever,

please let me know, but I'm going to undertake to

working on this probably Friday morning, tomorrow

morning.

THE COURT: And you don't see that it

 

Page 30


will cause a delay in the start of the impaneling of the jury?

MR. DRAKE: Not any significant delay.

THE COURT: Well, the word "significant"

is what bothers me.

MR. DRAKE: Well, I think it can be

filled out easily in 30 minutes.

MR. FRY: Of course, Your Honor, that

would bring up the question, just for our information, that it will take some time, though,

to collate that information.

MR. DRAKE: Right.

MR. FRY: So that the -- if you are

talking about -- just guessing, 150 or 120 jurors, even 100, that's quite a deal of information to go through one by one and make some kind of note of

what the appropriate responses are.   So, Jack, if I may ask, how were you going to propose to the Judge that we take time to use that information?

MR. DRAKE:  I propose that we adjourn

when the questionnaires are filled out, give us the remainder of Monday to evaluate the information.

THE COURT: That's not going to happen. That's not  going to take place. We are going to get

Page 31


started with the qualification of the jury, and you will have time to peruse it at breaks, at

lunchtime, and through the day, and before we are through with it. As a matter of fact, you have four attorneys sitting in the courtroom here.  You can assign a couple of lawyers to handle that.

MR. DRAKE: Judge, I always like to find the middle ground. Could maybe we start the voir dire, say, at 2 o'clock in the afternoon on Monday?

THE COURT: Well, we will decide that --

we will make a decision on it, we will make a decision on it in Tuscaloosa.

MR. DRAKE: All right.

THE COURT: Any other motions that could be considered at this time?

MR. DRAKE:  Yes. We had filed two

motions in limine. And those motions concern, in part, statements of other people. And I suppose trying to think of this as a trial, Judge, you might say, well, I'll wait until the witness is called to see if it's a problem, but what I'm suggesting is that the statements of Brenda Cerha and Janine Russelli and other people to whom Mr. White made statements prior to the murder, that the District

Page 32


Attorney be instructed not to refer to those statements in voir dire or in his opening

statement, until we get to a point in trial where

you can hear this testimony out of the presence of the jury and determine whether it's admissible or not.

THE COURT: Well, I don't see any problem with that. Do you, Mr. Fry?

MR. FRY: Well, Your Honor, I can live

with that, but certainly a pre-trial motion ih a hearing

THE COURT: Well, let me put it this way:

I think you are going to have to live with it unless the Court has first had the opportunity to hear it.

MR. FRY:  Yes , sir.

THE COURT: And I have not had that opportunity.  So unless you present it at this time and the Court has the opportunity to hear it, I

would not have enough, I would not know which way to rule on it.

MR. FRY: My only point was , Your Honor, there has been time to file motions to discuss

that.

THE COURT: I agree with that, but unless

 

Page 33


the evidence is presented here, then it would be appropriate to wait until the matter is taken up by the Court before it is mentioned to the jury.

MR. FRY: Yes, sir.

MR. DRAKE: Judge, the second motion in limine

THE COURT: my question is -- the next question, then, are you prepared to present that evidence at this time for a ruling by the Court?

MR. FRY: No, sir.

THE COURT: Then the motion in limine would be granted insofar as any mention to the jury in opening statement.

MR. FRY: In opening statement or voir dire?

THE COURT: Sure.

MR. DRAKE: Judge, the other ground and the second motion in limine refers to alleged extramarital affairs engaged in by Betty Wilson. And, again, the request is the same, that the District Attorney not mention it in voir dire or in opening statements.

THE COURT: It would be the same ruling. Until such time as the Court has had an opportunity

 

Page 34


to listen to the evidence itself    Any other

motions?

MR. COOK:   If Your Honor please, there is

one other matter in reference to a subpoena that

Your Honor authorized and which was directed to the custodian of the records at Brookwood Medical

Center back in November of this year, directing

them to produce to Mr. Hooper and to Mr. Sandlin, under certain conditions and restrictions as

imposed by the Court, the medical and hospital records of Mr. James White, also known as Mr. James Howell. Those records were never in fact produced and have not been received as of this moment.

However, only within the last three or four days, a motion for a protective order has been filed by Mr. Christopher Eagan of the law firm of

Starnes & Atchison, on behalf of the Brookwood Medical Center.  I have only seen that this

morning, and I notice in paragraph 4, which to me is probably the definitive portion of it, says, and I quote, "Counsel for the non-party has discussed production of these records with the Honorable Roy Miller, attorney for James Dennison White, also known as James Dennison Howell. Mr. Miller demands

 

Page 35


the records not be produced."

It is obvious to me that the reason the hospital is filing the motion for the protective order is really to protect themselves against any potential liability.

THE COURT: Mr. Cook, the motion to which you refer was faxed and received by the Court about five minutes before this hearing.

MR. COOK: Yes, sir.

THE COURT: Mr. Miller had a case before this Court earlier in the week and went home sick. And this morning called and said he is still sick.

So we need to get in touch with him.   But this

motion will be ruled on before we leave this

hearing or before the day

MR. COOK:  Let me give the Court     and I appreciate that, Your Honor, and I'm sorry that Mr. Miller is not well.

THE COURT: Let me ask Mr. Fry about that -motion. As I understood it, the order was entered previously without objection and by agreement.     You don't have any objection to that?

MR. FRY: No, Your Honor. Apparently the hospital, maybe under some federal law, has some

 

Page 36


kind of objection or maybe some kind of privacy violation. The State has no objection to it.  The State is not a party or had any kind of conversation with either the hospital or Mr. Miller. And we are not doing anything to obstruct that subpoena.

THE COURT:  When we complete the motions, we will take a recess and I'll call Mr. Miller at

his home, and we will --

MR. COOK:  I just wanted to give the

Court the -- the law is very clear on it.

THE COURT:  I don't have any question about its production.

MR. COOK: All right.

THE COURT:  But I think Mr. Miller is due

to be consulted.

MR. COOK: Absolutely.

THE COURT: The fact that he is sick -- otherwise we would ask him to come in and be heard, but since he is sick, I guess it would be

appropriate to just give him a call.

Okay. Are there any other motions, now,

at this time?

MR. FRY: Judge, we filed two motions in

Tuscaloosa and mailed you copies of them the same

Page 37


day. One was a motion in limine, the other was a motion to quash a subpoena.  They are, I guess you might say, housekeeping details, probably just the kind of thing I think is preliminary to trying a

case like this.

If I may, let me start with the motion to quash.

THE COURT:  Mr. Fry, I haven't seen the motions, I don't believe they have been received.

MR. HOOPER: Judge, we haven't got them, either.

THE COURT:  I don't believe the Court has received them.

MR. FRY: Well, Judge, they were mailed certified mail, I certified service.   I don't know why you haven't gotten them.

THE COURT: Janna, would you check with Carolyn and see if we have received any motions?   Dc you have copies of them?

MR. FRY: They are matters that could be reserved, Judge, until Monday, but I apologize, I don't know why you didn't have a copy.   I guess we could have hand-delivered it, but I thought the

mail from Huntsville to Athens would get it

Page 38


through.  Charlie, your copy was sent to Marc's address.

MR. SANDLIN:   I haven't got it yet.   it may come today, my mail doesn't come until around noon, and I didn't get it yesterday.

THE COURT: Do you gentlemen have any other motions?

MR. HOOPER: Judge, we have still got some outstanding, and probably one of those would concern Mr. Miller, also, and that's our petii:ion for a psychiatric examination of Mr. White.

THE COURT: All right. Now, Mr. Hooper, you gentlemen were told about three weeks ago, and

I don't know the exact date, but you were told that the Court was not favorably inclined to grant that motion.  The Court has not entered a formal ruling on that matter, but it is denied.

MR. HOOPER: Okay.

THE COURT:   That motion is not granted.

MR. HOOPER: Sure.

THE COURT: The motion, then, at this time, as a matter of record, is denied.

MR. HOOPER: Yes, sir. The State had opposed that; is that correct, if I recall?

Page 39


THE COURT:  I don't recall whether the State had opposed it or not, but the Court had indicated to you that it would not be granted.

MR. HOOPER: Judge, in addition we had a number of motions that were filed and outstanding since July of 192.

THE COURT: Mr. Hooper, I had discussed with you gentlemen on two or three different occasions, had entered a general order of

discovery, and have been told by you gentlemen in conference that there were no problems with any matters of discovery.  I don't know specifically

any specific matter that needs to be ruled on.

MR. HOOPER: Judge --

THE COURT: And the Court will be glad to

do that.

MR. HOOPER:  Sure.

THE COURT:  But I have been told that you

had no problems.

MR. HOOPER: Well, Judge, I attended some of those in-camera sessions, also, where there were problems.

THE COURT: Well, with the exception of the specific motions you filed, for example, the

Page 40


psychiatric examination, which will be ruled on.

MR. HOOPER: Judge, we have talked about original notes from the police department all the time, we have never gotten those.   All we have is compilations of what they decided later on after taking notes as to be their, I guess, document that they were going to present to us.  We have got a number of those things.

THE COURT:  Well, the Court has entered

an order requiring liberal discovery.

MR. HOOPER: Sure.

THE COURT:  If you have any problem with that, you were told to inform the Court

specifically.

MR. HOOPER: Judge, I have.   You know, we had a motion --

THE COURT: What is it that you want?

MR. HOOPER: We want his original notes, we want all of the police officer's original notes that they took in the course of this investigation.

THE COURT: Mr. Fry, can you respond?

MR. FRY: Judge, we have given everything that was requested.  I met -- offered to meet with these gentlemen on a state holiday to go through my

 

Page 41


file, but in fairness to them, my file doesn't

contain officer's original field notes.     And, to my knowledge, there was never an order of the Court directing that they produce those to the District Attorney's Office before I got into this case,

which would have been Mr. Brooks back then.     I have never had them in my possession, as far as I know, and I'm relatively certain that the DA's Office never had them in their possession.

MR. HOOPER: Judge, Ray is not limited to what's in his possession.    He can't hide it out in the police department.

THE COURT: Well, did you give him copies of them?

MR. FRY:  No, sir, I haven't seen

original -- unless there just happened to be some

in the file.   I think there may be some notes that were handwritten in hand and probably were field notes, but I haven't seen the little notes and the little stenographer's pads or whatever.     But I can say this:  Having worked with the officers for the last six weeks, I know of no exculpatory matter which could be contained, based upon having talked to the officers in preparation for this case.

 

Page 42


THE COURT:   Have you yourself used those? MR. FRY:   No, sir, I have not.

THE COURT:   Well, when we adjourn here

this morning, get with the officers and give the Court a report back this afternoon, so that if

there is any further order needed, there will be

time to do so.

Any other motions that need to be discussed at this time? Bear in mind, gentlemen, that matters that can be resolved here will save

time in Tuscaloosa.   The logistics of trying the

case in Tuscaloosa, with the witnesses, the

majority of them from this jurisdiction and others, is tremendous.

MR. DRAKE:  Judge, I had made a couple of notes of sort of housekeeping things.    If you have any instructions for us, we would like to know

about the way the courtroom will be run. I hear

from people in town that we will have an overflow crowd, not only of local spectators, but media people from all over the country, and courtroom management may be a problem.    If you want us to assist you or be aware of any rules, I would like to know about them.

Page 43


THE COURT: Mr. Drake, I haven't been in the courthouse in Tuscaloosa in several years, and

I don't remember what the courtroom even looks

like. I do not know what its capacity is.     I have a general idea.  So any information that you can give would be helpful.

MR. DRAKE: Now?

THE COURT: At any time. And anything

that you would like, both of you.

MR. FRY: Judge, we talk about capa'city.

I learned yesterday by someone --

THE COURT: As f ar as I am concerned, I know of no other way except first come, first

serve.  Now, if we have lineups outside bef ore daylight, I guess they will just -- maybe some of

it -- maybe the weather will discourage some of it. MR. DRAKE:   The courtroom will seat 230

people, if I remember correctly, and I think that's pretty well packed in.

MR. FRY: Jack, I was told yesterday that seating seven to a pew, that it would be about 136.

MR. DRAKE: I'm sorry, I meant 130.

MR. FRY: We have been told up to 200, but that was certainly out of line.

Page 44


MR. DRAKE: I checked, just like you did, and they expect between 80 and 100 jurors, so that part of the thing won't be as difficult as if we had a full turnup of the venire. But there will be --

THE COURT: Well, certainly during the qualification and selection of the jury, the jury itself will take up a big portion of the courtroom.

MR. DRAKE: That's right. That's one reason I brought this up, is just to alert you to

it.

THE COURT: All right. If you have any request to make, do so, and they will be

considered, because you practice in that court.

MR. DRAKE: Well, I was just thinking about things, about like a rule that people can't come and go during a witness' testimony, for example.

THE COURT: Well, we will do that, sure. MR. DRAKE: Sure. Have you talked with

the sheriff about the -- his role to play, the Tuscaloosa sheriff?

THE COURT: I have not. I have not.

MR. HOOPER: Judge, one other thing, housekeeping thing, also, is this: We had talked

 

Page 45


to the Sheriff's Office in Tuscaloosa as late as yesterday, and it was their understanding that our client would be transported to their facility on Friday. And, of course, we are going to be there

and we need to have access to her. We were informed this morning that she in fact may not be

transferred until the selection of the jury begins. THE COURT: That is not the case. An

order has been entered by this Court directing that she be transferred on Friday. That's tomorrow.

MR. HOOPER: All right. That takes care of that. Thank you, Judge.

THE COURT: Mr. Fry, anything else?

MR. FRY: Judge,. were you given a copy of this motion

THE COURT: No -- yeah, maybe, if Susan put it up here.

MR. FRY: I didn't notice it, either.

THE COURT: All right. Which one is it? MR. FRY: Motion to quash. If you like,

it's the shortest thing.  It, again, is kind of a housekeeping thing.

The motion basically is, Your Honor, that the sons and -- stepson, Perry Wilson, and the

Page 46


sons, Steve and Scott Wilson, have been subpoenaed in this case by the defense. They very well may be legitimate witnesses called by the defense, but if they are it's beyond the State's knowledge of what they could testify that would be relevant and also benefit the defendant. The State does not plan on calling them as witnesses.

Quite often, unfortunately, in my experience, the witnesses close to a victim have been subpoenaed to prevent them from being in the courtroom, for whatever reason that might be. All I'm asking in this motion to quash is some kind of guarantee, at least to satisfy the Judge, not necessarily in my hearing, that there is some legitimate reason why these young men have been subpoenaed so they would be excluded from the courtroom, and that otherwise it seems fair and equitable that they should be allowed to hear the case involving the murder of their father.

THE COURT: Well, first of all, the Court would not grant the motion to quash. Whether or not they would be excluded would be a matter of -- I assume we can take up at that time. However, if there is some problem with the attendance, it may

 

Page 47


be necessary to require them to be placed on call.

I have no problem with that.

MR. FRY: No, sir, there is no problem

with attendance.

THE COURT: You expect them to be there?

MR. FRY: Yes, sir.

THE COURT: Okay. All right. Well,

then, the only other question would be whether or not they are under the rule.

MR. FRY:  Yes, sir.

THE COURT: We will  take that up at the appropriate time. Now, your other motion?

MR. FRY: The other motion is a motion in limine, Your Honor. And, again, just looking at

the subpoenas -- I think there are something over 100 of them now that the defense side has issued -- seem to indicate some involvement or some taking of testimony from witnesses in regard to matters not involving the murder, but rather the estate of Dr. Jack Wilson.  Civil attorneys who are in matters collateral to his death have been subpoenaed and possibly, I think, one of Mr. Hooper's law partners has been subpoenaed. I'm not certain what the law is on that, but I thought in law school you weren't

 

Page 48


supposed to call law partners to be a witness in your case. But, at any rate, that law partner, I believe, has been involved in the estate over here involving Dr. Wilson. My motion simply says that the State will object and will ask the Judge to exclude matters relating to the estate matters, relating to things like movie rights, publication rights, things that are collateral to Dr. Wilson's death, but things that are not relevant to whether or not Betty Wilson killed or had killed her husband, Dr. Jack Wilson.

THE COURT: Your motion is to preclude mention by the defense counsel in opening argument.

MR. FRY: Yes, sir, voir dire, opening argument and also until a predicate or a ruling is had by the Court, would be in the case in chief, also, Your Honor.

THE COURT: Well, it would be -- the

Court would treat it the same as it did the motion in limine filed by the defendant.

MR. DRAKE:  Yes.  May I just -- so I understand what you are saying. Whether these matters are relevant with respect to a particular witness, we are not dealing here with today.  I

 

Page 49


mean, obviously, if a witness has a pecuniary interest in the proceeding, that's a matter of cross-examination, but the witness has to be put up first.  I mean, we can't get up and just start

talking about this out of thin air.

MR. FRY: And that is all I am asking for, Jack.

MR. DRAKE: You are only asking at this point that we not mention it in opening statement or voir dire?

MR. FRY: I'm asking that it not be mentioned until it's relevant or a ruling by the Court.

MR. DRAKE: Well, it would have to be,

anyway.

THE COURT:  Well, the ruling is the same

as the ruling made on your motions

MR. DRAKE: Right.

THE COURT: -- in limine.

MR. FRY: Your Honor --

THE COURT: So that the Court will, of necessity, need to hear the evidence before making

a ruling on it, and obviously if the evidence is not presented prior to opening statement, then there

Page 50


should be no mention of it. So your motion in limine is granted to that extent, likewise.

MR. FRY:  Yes, sir.  That is all I have, Your Honor.

THE COURT: Anything further from the

defendants?

MR. COOK: That is all, Your Honor.

MR. SANDLIN: There may be some things that would be proper to take up now, and it may be proper to take it up later.   I have been talking with Jim concerning some stipulations, we can put those on the record before we start the trial or we can do them now.  It won't take two minutes, whenever you decide to do it.

THE COURT:  If it won't take any longer

than that, we will do it.

MR. SANDLIN:  It's my understanding that the State has agreed that the medical records relating to James White are properly certified medical records.

MR. FRY:  Your Honor, we will stipulate to the records received under subpoena by Mr. Sandlin or the defense from the Veterans Administration are authentic records and we won't

 

Page 51


require a witness to come and authenticate those. Being a veteran and also a member of the Armed Forces, I can imagine the problems they could have having to get somebody from St. Louis or somewhere else, to come and authenticate a record that's 20 years old. So we will stipulate all of those   records received under subpoena under this Court, could be received as authentic documents.

MR. SANDLIN: Judge, we have also talked about phone records that were subpoenaed by us, as well as the-State. And we can, I believe, enter

into a stipulation that those are in fact authenticate records kept in the normal course of business at South Central Bell, or whatever the facility is. of course, we would reserve the right to object to the use of those records, for whatever purpose, during the trial. We would simply agree

to their authenticity at this point.

MR. HOOPER: Judge, that's limited to those records coming from South Central Bell.

MR. SANDLIN:  From the telephone company. MR. DRAKE: Can I clarify something about

the medical records? Mr. Fry only mentioned the Veterans Administration Hospital, and we know we

Page 52


have Brookwood records potentially. Are you agreeing to Brookwood, also?

MR. FRY:  Jack, all I was asked about was the Veterans records.

MR. SANDLIN: We didn't know about Brookwood when I talked to you.

MR. FRY:  If there are other records that are received under subpoena of this Court, and

after a reasonable inspection they appear to be a complete set of records or you gentlemen will

assure me that they are, we will stipulate to their admittance, also. Not admittance, but that they

are authentic.

MR. SANDLIN: okay. Judge, we have

talked about matters involving the chain of custody of the body of Dr. Jack Wilson, and we can eliminate the calling of several witness that handled his

body from the removal from the house to Dr. Embry,

to prevent the state from calling those witnesses. We do stipulate to the chain of custody on his body.

THE COURT: You want to do that at this time?

MR. SANDLIN: we can do that at this

time.

Page 53


THE COURT: Okay.

MR. SANDLIN: I have been talking with

Jim this morning concerning trying to enter into a stipulation concerning items of evidence that came out of the house, car, and other places. And we hopefully will have something to talk to you about

on that shortly. We haven't worked out a procedure on that, but we are working on it. I think that's

it.

THE COURT: All right. Anything fu'rther from the defendant?

MR.* COOK: No.

THE COURT: Anything further from the State?

MR. FRY: No, Your Honor.

THE COURT: All right. We are going to

take a recess and the Court will be in touch and communication with Mr. Miller concerning those records from Brookwood Hospital.

Now, you gentlemen stand by so that, if need be, we might have to have a conf erence by

phone. I have a speaker phone and we can all listen to Mr. Miller, but I'll get him on the phone first and we will make a decision, but stand by on that.

 

Page 54


And, then, Mr. Fry, what time would you be -- do you think you would be ready to discuss with defense counsel concerning the notes?

MR. FRY:  If I can work on that while you work on this other, I can give you a better idea.

It may be a matter of talking with one or two of the officers to see what's the better procedure to

follow.

THE COURT: All right. Let's check on

those records first.

MR. FRY: Yes, sir, I'll do that right

now.

THE COURT: Court's in recess.

(End of proceedings.)

 

 

 

 

 

 

 

 

 

 

Page 55


 

IN THE CIRCUIT COURT OF THE

SIXTH JUDICIAL CIRCUIT

IN AND FOR TUSCALOOSA COUNTY, ALABAMA

 

STATE OF ALABAMA              )

                              )

Vs                       )     CC92-1893

                         )

BETTY WOODS WILSON,           )

                              )

Defendant.          )

 

* * * * * * * * *

 

C A P T I 0 N

The above-entitled cause came on to be

heard before the Honorable Thomas N. Younger,

Judge, and jury, on the 22nd day of February, 1993,

commencing at 9: 10 a.m. , Tuscaloosa County

Courthouse, Tuscaloosa, Alabama, when the following

proceedings were had and done:

 

A P P E A R A N C E S

 

 

For the State:           Hon. Jimmy Pry

Hon.  Kristi Adcock

 

 

 

For the Defendant:       Hon.  Bobby Lee Cook

Hon.  Charles Hooper

Hon.  Marc Sandlin

Hon.  Jack Drake

 

 

 

Also Present:            Ms. Doris Turner,

Circuit Court Clerk

 

Page 56


P R 0 C E E D I N G S

(Whereupon , at 10 : 00 a m. , February 22,

1993, the following occurred in the Court's

chambers, out of the presence and hearing of the

jury venire:)

THE COURT:  Okay.  Now, Mr. Drake, I

believe you have --

MR. DRAKE: We had filed a motion, which

you ruled on Thursday in Huntsville, to prohibit

the prosecutor from referring to Betty Wilson's

extramarital affairs during voir dire or opening

statements. Since that time we have had time to

reflect and talk among ourselves, and we have

decided that we think we need to get into that on

voir dire, and rather than kind of spring it on Mr.

Fry, we are just going to withdraw the motion.

THE COURT: All right. Mr. Fry, of

course, you have no objection to that?

MR. FRY:  Sure.  I take it, also, you want

to withdraw your motion in limine as to Brenda

Cerha, while we are on a roll?

MR. DRAKE: No.

THE COURT: Okay, gentlemen.

MR. DRAKE: We would like to know, before

 

Page 57


he testifies, what kind of medication James White

is currently taking and what kind of medication he will be taking when he testifies, if any.

MR. FRY: None , that I am aware of , Jack. You can ask the deputies that have him down here.

If he has any, they would have it. But my understanding was he was under no medication.

MR. DRAKE: Well, I notice that Meyers

said he didn't need any as long as y1all kept him

locked up.

MR. FRY: Well, he has been locked up.

MR. HOOPER: i don't think you can shift

it on us to find it out. I mean, if he is taking medication, I believe --

MR. FRY: Charlie, I don't know, I didn't write the prescription.

MR. HOOPER: But you can inquire.

THE COURT: You can inquire and you will do that, won't you, Jimmy?

MR. FRY: Yes, sir, but all I know is to ask the people that brought him down here, and if he has got a prescription, he will have it with him. Lord knows if he needs it, he will need it today or

tomorrow.

 

Page 58


(Brief pause.)

THE COURT: All right. Now, gentlemen, Mr. Edger, to the left, and Mr. Johnson, both

deputy sheriffs from Madison County, and Janna Ifshun.  Now, all of these people have filed oaths

of office, but to be abundantly clear and for the record, I'm going to give them an oath at this time.

So, if each of you will raise your right hand.  Do each of you solemnly swear that you will honestly and faithfully perform the duties as'

bailiff in this case, State of Alabama and Betty Woods Wilson, the defendant in this case., to the best of your abilities, so hep you God?

MR. EDGER: I do.

MR. JOHNSON: I do.

MS. IFSHUN:  I do.

THE COURT: All right. Okay. Gentlemen, that will be it for the time being. Thank you.

Okay. What else?

MR. DRAKE: Judge, I feel like I should say this and I'm not trying to argue my case or anything

THE COURT: Well, one thing I  wanted to say before you get to that, what arrangements have

Page 59


you made to take these questionnaires and get

copies made?

MR. DRAKE: We have two people right out here, as soon as they are completed. We have already made arrangements with a commercial copier to do it on an expedited basis, and I hope we will have them back here in an hour.

THE COURT: And you are going to make a copy available to Jimmy?

MR. DRAKE: Yes, sir.

THE COURT: All right. Go ahead, Mr. Drake.

MR. DRAKE:  I like for Judges to know

where I'm headed.  And at the close of the State's case, we are going to make a motion for a finding and adjudication of not guilty.

THE COURT: Mr. Drake --

MR. DRAKE: That's not a pro forma

motion

THE COURT:  I have never been involved in many cases where that wasn't done.

MR. DRAKE:  I know, but I'm saying it's not pro forma, we are not trying to make a record.

If you read our brief , that the State has enormous

 

Page 60


 

corroboration problems --

THE COURT:  I understand. Mr. Fry?

MR. FRY: Yes, sir.

THE COURT: Anything else?

MR. FRY: Judge, it's a housekeeping detail, but more than that, also. I think the Court has waited until today to rule on the seating, on whether or not the sons of Dr. Wilson would be excluded from the courtroom. What I had asked, basically, was a showing, at least, to the Juage, that if they were going to be bona f ide witnesses

for the defense.  If not, it seems in all fairness they should be allowed to witness --

MR. COOK:  I can address that, and I can state in my place as an officer of the Court,'that our view is that they very well may be bona f ide witnesses, or subpoenaing them is in the utmost

good faith.  We have a basis in fact and a basis in law for doing so. And although I would be quite reluctant to tell you the reasons, if you insist, I would be more than happy to disclose it to the Judge in camera.

MR. FRY: No, I don't think so.    I think that is all I wanted to hear.

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THE COURT: Then, you are asking that who be excluded? They are asking that --

MR. FRY:  I filed a motion in limine,

Your Honor, to excuse the three sons who were subpoenaed.

THE COURT: Right.

MR. FRY: That motion was not granted, so

I suppose --

THE COURT: Well, ordinarily, of course, members of the family would be excluded from the rule. However, in view of Mr. Cook's statement, I think it would be wiser to exclude them.

MR. FRY:  Yes, sir.

THE COURT: Right.

MR. FRY: I understand.

THE COURT: Any other problems?

MR. FRY:  I have had cases, Your Honor, where I couldn't get the representation that Mr. Cook just made.

THE COURT: Right.

MR. FRY:  I wanted to clear that up.

THE COURT: All right. Mr. Sandlin?

MR. SANDLIN: No, sir.

THE COURT: Mr. Cook?

Page 62


MR. COOK: No, Your Honor.  Thank you.

THE COURT: Mr. Hooper?

MR. HOOPER: No, sir.

THE COURT: Mr. Drake?

MR. DRAKE: No, sir.

(Whereupon, proceedings were in recess at 9:25 a.m., until 1:15 p.m., at which time, with a jury venire and all parties present, the following occurred:)

THE COURT: Ladies and gentlemen, I"m Tom Younger from Huntsville.  I'm pleased to be with

you today for the trial of a case. I hope it won't take too long.

Mrs. Turner has given you your oath, I believe, that you took this morning, touching your qualifications as jurors.  I have a few more questions that I need to ask before we get

completed.

But, first, the case that we are trying

is a case wherein the defendant, Betty Woods

Wilson, is charged by indictment with capital

murder.  This case was transferred to Tuscaloosa County from Madison County.

The defendant is represented by Jack

Page 63


Drake, seated here at the table to your right. Mr. Drake practices here in Tuscaloosa. Also, Marc Sandlin and Charles Hooper. Both of these

gentlemen are from Huntsville. And, also, Bobby

Lee Cook from Summerville, Georgia.

The case is being prosecuted by Jimmy

Fry, District Attorney from Athens. And he is assisted by Kristi Adcock. She is an Assistant District Attorney in Mr. Fry's office.

The indictment in this case, ladies and gentlemen, was returned by the grand jury of

Madison County in July of last year, July 192. I'm sure none of you were members of that grand jury, else you would not be here in this courtroom, but

for the record, if any of you were, would you please raise your hand.

(No audible response.)

THE COURT: Also for the record, ladies and gentlemen -- I'm sure some of these questions

may have been asked by Judge Karrh in his earlier examination. And, for the record, have any of you ever been convicted of a felony? And, if so, please raise your hand.

(No audible response.)

Page 64


THE COURT: Have any of you ladies and gentlemen been indicted within the past 12 months for a felony or some offense similar to the one with which this defendant is charged? And, if so,

please raise your hand.

(No audible response.)

THE COURT:  Are any of you ladies and gentlemen related by blood or marriage to the defendant, Betty Wilson Woods, or to the

MR. DRAKE: Excuse, me, Judge. it's

Betty Woods Wilson.

THE COURT:  Betty Woods Wilson.   Thank you, Jack.

If any of you are related by blood or marriage to the defendant, Betty Woods Wilson, please raise your hand, or the alleged victim in this case, Jack W. Wilson.  And if any of you are so related, please let that be known.

(No audible response.)

THE COURT:  Do any of you ladies and gentlemen have an interest in the conviction or the acquittal of this defendant, or have any of you

made any promise or given any assurance that you would convict or acquit the defendant in this case?

Page 65


And, if so, please raise your hand.

(No audible response.)

THE COURT:  Do any of you ladies and gentlemen have a fixed opinion concerning the guilt or the innocence of this defendant which would bias your verdict? If so, please raise your hand.

(No audible response.)

THE COURT: Are any of you ladies and gentlemen opposed to penitentiary punishment, that is, punishment by imprisonment in the penitentiary? And if any of you are so opposed, please raise your hand.

(No audible response.)

THE COURT: Are any of you ladies and gentlemen opposed to capital punishment? And if

any of you are opposed to capital punishment, let

it be known at this time by a show of hands. If you are opposed to capital punishment, please raise

your hand.

Would you please stand, please, ma'am,

and identify yourself?

JUROR: My name is Debbie Little.

THE COURT: All right. Thank you very much.

 

Page 66


 

Now, ladies and gentlemen, the attorneys in this case -- the jury will be selected by' the struck jury system, meaning that a jury will be selected from your number, with the remainder being eliminated by a process of striking, with the parties striking alternately until that number remains.  In order to do this, the attorneys need to identify you with the name that they have on their list. So for that purpose, as Mrs. Turner calls

your name, would you please stand and tell us where you work.  If your wife is employed outside of the home, please state her employment. Otherwise, you may -- might only state that she is a housewife.   it is for the purpose of identification only that we

ask you to do this.  So that the attorneys and the parties in this case will be able to select a jury. So as Mrs. Turner calls your name, please stand and give us that information.

(Whereupon, the clerk called the roll of the jury venire, and the prospective jurors gave

the requested information.)

MRS. TURNER: Any jurors' names I did not call?

(No audible response.)

Page 67


THE COURT: Mr. Fry, are you ready?

MR. FRY: Yes, sir, I am, Your Honor. (Whereupon, Mr. Fry conducted a voir dire

examination of the jury venire as follows:)

MR. FRY:  Good afternoon.   I have been waiting all day to see you all.   You all have been waiting all day on us, too, haven't you.

My name is Jimmy Fry, as Judge Younger told you, and I'm here today visiting.    I'm going to be here probably all week and probably some of next week, visiting, also.   I'm the district attorney in Limestone County, Alabama, and I have been assigned to come to Tuscaloosa and try this case,

representing the State of Alabama, that is, the people of the State of Alabama.

The Judge has explained to you a little bit, I guess, about that this is a case that

happened in Huntsville.   well, my office is in Athens, so I'm not even from Huntsville.    The District Attorney over in Huntsville was unable to try this case for a legal reason.    And so I got assigned to try it by the Attorney General, that

is, Jimmy Evans, the Attorney General of the State

of Alabama.   I brought some people with me this week

Page 68


from home to help me on this case. And some of you, 12 -- or 14 of you, anyway, are going to be seeing some of them come and go as this trial gets underway and progresses. It may be that the defense lawyers are going to want to know if you all know any of the people helping me. So I would like to introduce

them to you from the very beginning. Some of my friends from my office that work with me in the DA's office in Limestone County are here. Beginning

with Mr. Bobby Smith, who is an investigator.' He is

an investigator from my office. Been with our office for about 15 years. Helping me on the legal end some, probably as much out of the courtroom as

in the courtroom, is Miss Kristi Adcock. You have already met Kristi. She is the only other lawyer working in my office in Athens. And also from my office this week, we have our victims service officer, Mrs. Sally Marks. While we are in here working, Sally will be outside of the courtroom

most of the time, hopefully keeping our witnesses

in line and ready to come in, where we can have an orderly trial and, also, providing, of course, for the overnight stays and that kind of thing for witnesses who are from out of town. Of course, all

Page 69


of the witnesses, as far as I know, at least most of them, are going to be from out of town.  Madison County, Morgan County, Marshall County. And so

they have to be put up when they come down here, and that's what Mrs. Marks is going to be doing for us.

In addition, we have some folks who have been loaned to me for this trial from the

Huntsville District Attorney's Office. And in the

courtroom with us this afternoon, we have Wanda

F a r r i s .Wanda, if you will, stand. Wanda is also a VSO, and although not directly involved in the

trial of this case, she will be assisting Mrs.

marks on providing transportation and lodging and whatever comfort we can to the people who will be coming down to testify. Also, Mr. Larry Smith, he is an investigator from the District Attorney's office in Huntsville, and Larry is not here.    Larry is working right now, as I speak, on something for me. He is a big, big guy, my size and half over again, with gray hair.  You will recognize him when he comes in. He will take half the door when he comes through it.

Also, we have one other person that is with me.  We have an investigator from the

Page 70


 

Huntsville Police Department who was the chief detective assigned to this case.   Six weeks ago he was unknown to me; today I'm proud to call him my friend. Investigator Micky Brantley is here, also from Huntsville.

In addition, let me just say one very brief note of thanks for District Attorney Charlie Freeman, your District Attorney, who has been a gracious host to me and the people working with me today, and even before we got down here.

As you can imagine, working without an office, working without a library or a copying machine or anything else, can be something of a problem. Mr. Freeman has very graciously given us

a working space and helped us in doing our job down here while we are visiting with you all.

First of all, let me begin this afternoon by thanking you all for the sacrifice which you

have made to be here. Now, I know everybody on this jury panel had somewhere else they could have been this afternoon, whether it's family or your job or some of you lucky retired people, maybe your hobby. Lord knows, you all could be gardening down here as warm as it is, planting cabbage and turnips.     I

Page 71


don't know what all -- onions.  And all of you had something else you could have been doing.    I have

got a family and obligations back in Athens, and

I'm sensitive to the sacrifice you all are making

to be here with us for this trial.

And I want to begin by congratulating you and thanking you for making the sacrifice and for giving of your precious time in the fulfilling of this very special duty and obligation of

citizenship, that is, jury duty.

Now, what are we going to do here this afternoon? What we are doing is called voir dire. Voir dire, as I understand it, comes from a French word or Latin word or phrase meaning to speak the truth. And I read that in a book somewhere.    I

don't know if that's really true or not, but I know what it means to me.  To me it means that I get to speak with you all.  We get to talk together, like

we would say in Limestone County, we get to visit a little. And I like this part of the trial.    Later

on 12 or 14 of you will get to hear the lawyers

talk, but you won't get to talk with us.   Basically, you will be listening.   So this gives us a chance to talk just a little bit.

Page 72


I don't know any of you. I don't know anybody on this jury panel. This is a funny fee1ing.I have been sriking juries for 12 years at home, and I always know somebody.   I always know several of you.  I don't know any of you all and, as far as I know, none of you all know me.  So we are going to have to get to know each other just a ittle bit so I can strike this jury.   Because what we are preparing to do, what we are getting ready to do, is strike a jury, a jury in a criminal case, a jury in a murder case, a jury in a capital murder case, to be exact. And we need to know something about you all. We need to know probably a little bit more than what we just got by you all standing and introducing yourselves.

This is a capital murder case and it is

as serious as it gets.  So I want you all to share with me a little bit and answer some questions

which I'm about to ask. And, by the way, I'll try not to ask you any of the questions that were on the survey. My questions may shade just a little bit, but I'll do my very best not to ask you anything

that I'm going to have to go through tonight on that stack of papers that fit.

Page 73


OOkay. we are going to pick this jury and we are picking this jury for one particular case.

The jury we pick, as far as I know, is going to hear one case before that jury is released.   And the jury we pick is to hear this one unique case where there is one unique fact.  We are not necessarily looking in this case for the most intelligent people or the most educated people or the best looking people.

It may turn out that way, maybe that's what we will get. But what we are looking for, ladies and gentlemen, are some people who we think can be objective.

Now, what do I mean by objective? I mean that you have no firsthand knowledge of the facts

of this case, that is, you were not a witness or you were not present up in Huntsville, Alabama, May the 22nd, 1992, when Dr. Jack Wilson was murdered.    You have no relationship to either the defendant in

this case or the victim or me or anybody directly involved with the trial of the case.   Finally, you have no special reason why you should not serve on this case.  For instance, perhaps you, yourself,

have been a victim of a crime or had a special circumstance in your life that would make this a

Page 74


very difficult, if not impossible, case for you to hear.

Now, I'm not going to ask you any questions this afternoon intended to embarrass you or to humiliate you or to offend anyone in the courtroom.  Please understand that my questions are not suggesting that anybody in this courtroom on

the jury panel would either be unfair or dishonest. We have just got to get to know each other a little bit.  The questions which I'm just about to a6k you are very important to me, I promise you they are.

I'm not doing this just for the fun of it.  The questions are important to me.  I won't ask you any questions that are not important to me. Your

answers are important to me and I have to not only know your answers, your answers have to be recorded by A.D., our court reporter here. So I'm going to ask you to do something for me.  If I ask you a question and that question applies to you, I want you to raise your hand right where you are, and, if you will., please raise it high enough so I can see it.  It's just a whole sea of you all out there, and I may miss one if you just give me one of those little weak numbers there.  So if it applies to you,

Page 75


raise your hand, and then if you will pardon my pointing, I'll point to you and get your name so

A.D. can get it down on tape, and then we will let you answer the question.

All right.  The Judge has asked you if

you are related to the defendant in this case. None of you were. Now, I want to ask any of you do you know or are you acquainted with the defendant in

this case? The defendant is, as the Judge said, Betty Woods Wilson. Now, my understanding is Mrs. Wilson grew up in Gadsden, that her maiden name was Betty Woods. After high school she was married to a gentleman by the name of Sonny Taylor, she has

three children, three boys, who are Bo, Dink, and Trey Taylor. She was married in the late 170s, I believe, to Dr. Jack Wilson in Huntsville.  You

will hear that Dr. Wilson was a prominent ophthalmologist there, and she lived there with Dr. Wilson until May 22nd of last year.

With that background, do any of you know or do any of you have any reason to know the defendant in this case, Betty Wilson?

(No response.)

MR. FRY: All right.   She has four

Page 76


attorneys with her this afternoon, and I want to

ask if any of you know any of them. And let me take them in order. First, Mr. Cook, Mr. Bobby Lee Cook, is an attorney from Summerville, Georgia. He practices in Summerville, but his practice is not limited to Summerville, Georgia, nor the state of Georgia. I don't expect that you would know him or would have had dealings with Mr. Cook, but you may have, it's a small world. Do any of you know Mr. Cook? Have any of you ever had any dealings or any acquaintance with Mr. Bobby Lee Cook?

(No response.)

MR. FRY: Another attorney representing

the defendant in this case is Marc Sandlin. Now, Marc, as the Judge said, practices law in

Huntsville, Alabama, and has for probably the last 10 or 11 years, but Marc, if I'm not mistaken, was

an undergraduate here at the University and also attended the law school here. So he must have spent at least seven years here, maybe more than that.

MR. SANDLIN: Just seven.

MR. FRY: Just seven. Okay. Do any of

you know Marc Sandlin? Did all of you see him when he stood a moment ago?

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(No response.)

MR. FRY: Nobody knows Marc. Well, let's see if I do any better with this one. Mr. Drake.

Mr. Drake, now, he is a Tuscaloosa lawyer. Mr. Drake, I understand, has been practicing here for

several years or many years.

MR. DRAKE: 23.

MR. FRY:  23 years. That would qualify for many, I guess. And he, I think, also went to school at Alabama and also went to law school at Alabama, and has a law practice here. Do any of you know Mr. Drake? Okay, I see a few hands.  Put your hand down just a moment and let me add onto that

just a little bit. What I mean by knowing him is this: If you were at the Red Lobster and you saw Jack across the salad bar, or whatever -- I don't think they have one at Red Lobster -- but if you saw him in the line at Red Lobster, maybe at The

Landing, you saw him at The Landing and you were at the salad bar, do you know him well enough to say, "Hey, Jack," or do you know him because either you or someone close to you has had some kind of either business or social relationship with him? By that

I mean, have you got a relative maybe that was

Page 78


involved in a lawsuit in which Mr. Drake was on either side of the case, or maybe through the local Democratic party or some political organization?

Do any of you have any association with Mr. Drake? Now, let's start, again, with the hands.

And, I tell you, there are so many of them, let's take the right hand first.   My right side first. Okay.  Now, you are Mr. Drake?

A JUROR: Yes, sir.

MR. FRY: Are you related to him?

A JUROR: No, I'm not. I served on a jury about two and a half , three years ago, that Mr.

Drake represented one of the sides.

MR. FRY: Okay.

A JUROR: That's my only real dealing

with him.

MR. FRY:  Criminal case or civil case?

A JUROR:  It was concerning a will.

MR. FRY:  Concerning a will?

A JUROR:  Civil case.

MR. FRY:  All right. Thank you, sir.

Working our way back. Yes, sir.

A JUROR: He represented me in a case

once and I have been knowing him since he was in

Page 79


 college at the university.   I was a policeman out there for 12 years.

MR. FRY:  And your name, please, sir?

A JUROR:  Davis Nichols.

MR. FRY:  Mr. Nichols. Thank you, Mr. Nichols.   I saw another one, I thought, back there. Did I not? Was that somebody scratching? on this side, I saw several hands.   Yes, sir.

A JUROR:  Mr. Drake is an acquaintance of mine.  I also know his wife and his partner.

MR. FRY:  Your name is Burton?

A JUROR: Burton King Curry.

MR. FRY: All right. Thank you. Yes, ma’am.

A JUROR:  Hendrix.   He represented me in the past.

MR. FRY:  He has been your lawyer before? A JUROR:  Yes.

MR. FRY:  All right, Mrs. Hendrix.    I thought I  saw some more hands.  Mr. Robinson.

A JUROR:  Jack and I were business neighbors  about 20, 25 years, out on University Boulevard  there.

MR. FRY:  Okay.  Anybody else? Yes, sir.

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A JUROR: Morgan Tunstall.  I have

treated his daughter orthodontically about 20 years ago, and I say hi to him every time I see him.

MR. FRY: All right. That's exactly what

I was talking about. Those of you that know Mr. Drake in any form or fashion. Is there anyone whose relationship with him is such that it would make it difficult for you to sit on a jury in which he was representing one of the sides, without being prone to lean towards his side of the house just be6ause

of your relationship with him? Anybody?

(No response.)

MR. FRY: Mrs. Hendrix, he was your

lawyer. Would you be able to sit on a jury --

A JUROR: Yes.

MR. FRY: -- and be fair and impartial?

A JUROR: Yes.

MR. FRY: All right, I believe you would. I'm coming to you, Charlie, I didn't mean

to leave you out.

MR. HOOPER: That's all right, Jimmy.

MR. FRY: Mr. Charlie Hooper is another Huntsville lawyer, he practices in Huntsville. And I believe mostly Huntsville or maybe North Alabama.

Page 81


He has got some partners up there with him, George Beason and Doug Martinson. And I don't know that

any of you should know any of them, but I don't

know, Huntsville is just right up the road, you all may know some of them. Do any of you know either Charlie Hooper, George Beason, or Doug Martinson?

(No response.)

MR. FRY: Jack, I'm sorry, you have a partner, do you not?

MR. DRAKE: Joe Pierce.

MR. FRY: Do any of you know Mr. Joe Pierce? Is he here?

MR. DRAKE: He is right there.

MR. FRY: That's Joe. Okay. Mr. --  you know Mr. Pierce, also?

A JUROR: Yes, sir, I do. We have had some business dealings, real estate dealings and office dealings.

MR. FRY: And your last name?

A JUROR: King Curry.

MR. FRY:  I'm sorry. Did I see some other hands? All right. All right, moving along here.    I want to ask you something about the facts of this case. I'm not going to tell you the case, we will

Page 82


 

do that when we start the trial tomorrow, but the judge just asked you do you know anything about it. I'm going to tell you just a little bit more about the facts, just to see if you heard anything about this case. I'm not going to argue the case to you. But this case is going to involve Dr. Jack Wilson. Dr. Jack Wilson being found dead at his home at 2700 Boulder Street in Huntsville, Alabama, found by his wife, the defendant, Betty Wilson, back on the 22nd of May last year. That is, 1992.   And Dr. Wilson

was found dead, apparently from being beaten with a baseball bat or softball bat and stabbed with a knife. Now, having given you just a little bit more of the facts, do any of you know anything about this case? Do any of you have any firsthand knowledge or have you talked with someone involved in either the prosecution or the defense of the case? Have any of you discussed this case with anyone in an official capacity? In other words, when you found out you were on the jury service, did you call your friend the Chief of Police, or your friend the Sheriff or somebody, and say, "What is this about, you know, what have I gotten into, get me out of this”? Yes, sir, who?

Page 83


 

A JUROR: I saw Mr. Drake yesterday at

the gasoline station. Immediately when he recognized me, he said, "We can't talk." I said, "I don't think I'll be on the jury, anyway." That was it.

MR. FRY: Well, you never know, Mr.

Curry. You are on there so far, aren't you?

A JUROR: Yes, sir.

MR. FRY: Thank you. Anybody else?

(No response.)

MR. FRY: How many of you have read about this case in the newspaper? I believe that was on your survey and I'm not going to get into any

detail, but could I just see your hands?

All right. Let me do it the other way.

How many of you have not read anything about this case? Looks like about half and half - Thank you.

How many of you have seen anything about this case on either the television or heard

anything about this case on the radio? A few more hands. I don't believe that's on the survey, is it,

TV and radio?

MR. COOK:  I don't watch TV.  I don't

know.

Page 84


 

MR. FRY:   I don't either.   I don't think that was on the survey about TV and radio.     I just think it said newspapers.    Could I see the hands on this side, again? Would you give me your name, please, sir?

A JUROR:   James Collins.

MR. FRY:   TV or radio.

A JUROR:   No, newspaper.

MR. FRY:   Newspaper. Okay. Just TV or radio now.   Yes, ma'am.

A JUROR: TV and radio.

MR. FRY:   And your name?

A JUROR:   Donna Johnston.

MR. FRY:   Johnson or Johnston?

A JUROR:   --s-t-o-n.

MR. FRY:   Yes, sir.

A JUROR:   Tom Floyd. Television.

MR. FRY:   Television?

A JUROR:   Yes.

MR. FRY:   All right. Yes, ma'am.

A JUROR:   Aleen Costes -- Laura. I'm sorry.   Laura Costes.    Television.

MR. FRY: Yes, sir.

A JUROR: Television.

Page 85


MR. FRY:  Television.   Yes, sir, Mr. Nichols.

A JUROR: Nichols. Radio.

MR. FRY:  Radio.   Yes, sir.

A JUROR:  Radio and TV.

MR. FRY:  Radio and TV. Mr. Latham.

A JUROR:  No, James Wilkinson.

MR. FRY:  I'm sorry, Mr. Wilkinson.

A JUROR:  Television and newspaper.

MR. FRY:  TV and newspaper.    Yes, ma’am.

A JUROR:  TV and newspaper.

MR. FRY:  The lady behind you.

A JUROR:  Gala Walker. TV and newspaper. MR. FRY:  TV and newspaper. Ms. Little,

Debbie Little.

A JUROR:  Yeah, television.

MR. FRY:  Television. Yes, ma'am.

A JUROR:  Phyllis Cook, television and radio.

MR. FRY:  And your last name?

A JUROR:  Cook.

MR. FRY:  Mrs. Cook, TV and radio. Yes, sir.

A JUROR: Television.

Page 86


MR. FRY: TV. Anybody else? Lady in the back.

A JUROR: Today's TV news.

MR. FRY:  Today's TV news. All right. Forgive me, but your name, please, ma'am?

A JUROR:  Spencer.

MR. FRY:  I should have remembered your name.  I'm sorry. over here, now, radio or TV, not newspaper?

A JUROR:  TV. Herbert Bruce.

MR. FRY:  Yes, sir.

A JUROR:  Fred Darnell, TV.

MR. FRY:  Mr. Darnell. Yes, ma'am.

A JUROR:  Judy Lamon, TV.

MR. FRY:  Mrs. Lamon.   I'm sorry I

skipped you all. Mr. Hine?

A JUROR: TV.

MR. FRY:  Yes, ma'am.

A JUROR:  Margene Hinton, TV.

MR. FRY:  Mrs. Hinton.   TV.  Ms. Kizziah. A JUROR:  TV and radio.

MR. FRY:  TV and radio.   Let's see.   Yes, sir, Mr. Robinson.

A JUROR:  TV and newspapers.

Page 87


MR.- FRY: TV and newspapers .  Yes, ma'am. A JUROR:  Lueguster Robinson, the radio. MR. FRY:  Radio.  Yes, sir.

A JUROR:  William Porter, the radio and TV.

MR. FRY:  Radio and TV?

A JUROR:  Yeah.

MR. FRY:  Going in the back, this back here. Yes, ma'am.

A JUROR:  Stephanie Turner, radio.

MR. FRY:  Ms. Turner, radio.   Yes, sir.

A JUROR:  Morgan Tunstall, TV.

MR. FRY:  Dr. Tunstall, TV. Yes, ma'am.

A JUROR:  Doris Townsend, TV.

MR. FRY:  Yes, ma'am.

A JUROR:  Bernice Stewart, TV.

MR. FRY:  Mrs. Stewart, television. All the way to the back.   Mrs. Yourick.

A JUROR:  TV and radio.

MR. FRY:  TV and radio.   Have any of you

on the jury panel heard anything on either the TV or the radio that cannot be set aside? Have any of you heard anything on either TV, radio, or the

newspaper that has already -- that has made you

Page 88


make up your mind about what you would do in the

case?

(No response.)

MR. FRY:  Is there anybody sitting here

right now that thinks that the defendant in this

case is either guilty or probably guilty? Mrs. Yourick, you have got your hand up back there.

A JUROR:  I have formed an opinion.  I'm not sure it will stick, but I have.

MR. FRY: Could you sit on a jury, Ars. Yourick, and listen to the evidence and decide the case based on the evidence that you hear as a part

of the jury and based on the evidence that the Judge would explain to you, do you think, or is there something already in your mind that is so overwhelming that you feel like you would not be

able to set that aside?

A JUROR:  I'm not real sure I could set it aside.

MR. FRY: All right. Well, I appreciate your honesty.  Voir dire means to speak the truth,

that's what we are here for.  Nobody is going to be criticized for speaking the truth today, I promise

you. Yes, ma'am.

Page 89


A JUROR: What I have read in the newspapers, there is a possibility I think she is guilty, but I'm not absolutely sure, but there is a doubt in my mind.

MR. FRY: Okay.

A JUROR: Burns.

MR. FRY: Mrs. Burns. My question is, would you be able to put that doubt aside and base a verdict, if you were on the jury, based on what you saw and heard in court and not something you have heard or seen in the media?

A JUROR:  I think I could be objective. MR. FRY:  Okay, Mrs. Burns, thank you.

Yes, sir.

A JUROR:  I'm basically the same way.    I read quite a bit about it and from up in the Huntsville Times, the Huntsville papers and all,

and I heard it when I was up there visiting.

MR. FRY:  So you have read some

Huntsville coverage of it?

A JUROR:  Yes, sir.

MR. FRY:  I'm sorry.   Your name?

A JUROR:  Porter.

MR. FRY:  Mr. Porter.

Page 90


A JUROR: Yes.  I seen it on TV up there and heard it on radio.

(Brief pause.)

MR. FRY: Continuing on. I want to ask you some questions now to really get to your

feelings about serving on the jury and your

feelings about the law and your ability to -- and your willingness to follow the law in this case. By the way, you all loosen up a little bit. Some of

you all got your backs and necks so tight Ilmafraid you are going to pop. Nobody is going to be

throwing anything at you or doing anything to scare you. I'm not going to be shooting a pistol or cracking a whip or anything.

This case, ladies and gentlemen, is going to involve the sudden violent and hideous death of another human being, Dr. Jack Wilson. Now, there

is always unpleasantness in a murder case, and this case is no exception to that. There will be, by necessity in a murder case, also grotesque and gruesome evidence.  It's just not a pleasant thing, it's an unpleasant thing. No doubt everybody on this jury panel or at least every normal person on this jury panel has strong feelings about death.

Page 91


And everyone has, I'm sure, strong feelings about someone dying suddenly and unexpectedly without reason.   But is there anyone on the panel, because

of some experience that perhaps you or someone

close to you has had, feels like this is just a case that you do not want to hear? Now, I'm not going to ask you why, I'm not going to pry as to why you

might not want to hear this particular case.     Yes,

ma’am.

A JUROR: I just prefer not to.

MR. FRY: And your name?

A JUROR:  Lois Lindsey.

MR. FRY:  Mrs. Lindsey?

A JUROR:  Yes.

MR. FRY:  Anyone else?

(No response.)

MR. FRY: Judge Younger is going to

explain to the 12 or 14 of you all who get chosen to be on this jury, what the law is in this case.    Now, no one here today is expected  or required to know

the law. Quite the opposite. The law will be given to you all by the Judge at the end of the trial, not by me, not by Mr. Drake or Mr. Cook, only the Judge . But he will instruct you that you are required by

Page 92


your oath and the law of this State to apply the law, which he explains to you, to the facts, which you and only you will find and decide to be true, and then and only then arrive at a verdict.

Will each of you give me your promise that if you are selected to be on this jury, that you will take the law that he gives you and, to the best of your ability, apply it in this case?

(No response.)

MR. FRY:   You may say, well, why do you ask that? Well, because sometimes, even though you take an oath and even though you have an obligation to follow the law of this state, there are people who get on juries who decide they will change the law, they have got a better idea about what the law should be. That maybe there is some kind of unwritten law that they can come up with on their own.  Kind of like I used to do in geometry, the teacher was always trying to get me to memorize the formula, you know, to make the lines all meet up in the end, and I always tried to come up with my formulas, because I couldn't remember the formulas. Well, in this case you will be explained the law.

Is there anyone on the jury panel who can't live

Page 93


 

 

with that? Is there anyone, because of your

personal philosophy or because of your personal religion, beliefs, just believes that the

individual ought to be able to decide for

themselves what the law is?

(No response.)

MR. FRY:  The Judge will charge the

people selected as jurors, that they are to weigh

the testimony of the case using their common sense and without sympathy or prejudice. Can each of you give me your promise that if you are chosen for this jury you will do that? You would weigh the evidence using your God-given common sense and without sympathy or prejudice?

(No response.)

MR. FRY:  I take your silence to mean

that you would.

Let me say something to you about circumstantial evidence.  Now, normally the

think in other charges to the venire that I have heard, circumstantial evidence is mentioned.   I don't believe it was mentioned this morning by the Judge, but I believe it will be an important

element of the jury charge as given at the

Page 94


 

conclusion of this case. So I would like to talk a little bit about it, and then ask you a question or two about circumstantial evidence.

What is circumstantial evidence, what is it, what is it not? You hear a lot about circumstantial evidence. Well, circumstantial evidence is evidence based upon something not

direct evidence, that tends to prove a fact. I

could illustrate better than I can explain.  First, let me give you an illustration of direct eviaence. Let's say I'm at the Kmart at home and I know a guy,

I have known him all my life, and I see him rob Kmart, and I see him do that, I see him run away and he gets away.  Later on I tell the police, "Yes, I saw him, I know it was him, I have known him all my life." That's direct evidence.   I identified the person positively as the person that committed the crime.  I would be called as a witness to testify, "Yes, I saw him.  I knew it was him-"

Take this same example and let's say that it's snowing in Athens, which is possible. That happens about once a year.  And let's say instead of being able to positively identify this person, this person has on a ski mask, a big heavy Army coat, so

Page 95


I can't see their features or face and I can't positively identify this person as my friend that I have known all my life.   But I notice, as they

leave, they have got a limp, and I can say I don't know it was my friend, but it certainly looked like the limp, I can identify that, I think that's my friend because of the limp.    That's just a circumstance that tends to prove that it was my friend.   I can't say positive that it was.

Let me get back to the snow example again for you.  Let*11s say you are walking across a snow- covered bridge. All right. And as you get to the end of the bridge you notice parallel to you and across the bridge some little tracks, and you get

to the edge of the bridge where these tracks end, there is a child sitting up on a rail with some little red boots on. Now, you didn't see the child cross the bridge, he is just sitting there.     You didn't see the child make the tracks. The child is there, the tracks are there. That would be circumstantial evidence that the child did in fact cross the bridge.

At the conclusion of this trial, ladies and gentlemen, the Judge, I believe, will explain

Page 96


 

to you that circumstantial evidence is good evidence, not inferred evidence. And that a conviction can be had on the basis of

circumstantial evidence, if the State meets its burden.

Now, I want to ask you a question based

on that, and it's very important to me.     Is there anyone on the jury panel who would not consider circumstantial evidence?

(No response.)

MR. FRY: We hear people say sometimes, "Well, you know, if I was on a jury I wouldn't ever convict on circumstantial evidence; it would take more than that.   I would have to have positive direct proof . 11 Anyone on this jury panel, if they were convinced of the defendant's guilt after the Judge had explained to you what the burden of proof is, is there anyone who would, nonetheless, be hesitant to convict   on the basis that most

excuse me -- much of the evidence, not most       much of the evidence was circumstantial?

A JUROR:  Debbie Little.

MR. FRY:  Ms. Little?

A JUROR:  I think I would have a problem

Page 97


with it. It would be hard to make a decision.

MR. FRY: Okay. Another important

element of this case, something that the jury that hears this case is going to have to wrestle with,

and I'm going to have to wrestle with, is the burden of proof, that is, the burden on the State of

Alabama which today and this week is going to be on Jimmy Fry, me, to prove this defendant guilty.   And to prove it with the standard that the Judge is

going to explain to you.                      t

It's going to be something like this:

That there is a presumption of innocence that

follows this defendant throughout the trial and until her guilt is established by the evidence

beyond a reasonable doubt, she is presumed not guilty. We must prove -- the State must prove every essential element of the crime charged.   And to

find the defendant guilty, the jury must be

convinced beyond a reasonable doubt and to a moral certainty of the defendant's guilt, of each and every element of the crime charged.   However,

notice this, please, this is important. The Court, the Judge, will tell the jury, I believe in the closing instructions, that the State is not

Page 98


required to prove this defendant or any defendant guilty beyond all doubt. That in fact very few things in life can be proven --

MR. DRAKE: Now, Judge, I object to this. This is argument.  I think it goes beyond the bounds of voir dire. He is arguing legal principles to the jury.

THE COURT: Mr. Fry, you about through? MR. FRY:  Yes, sir, I have just got one

question to follow up on.

THE COURT: All right.

MR. FRY: Thank you. My question is

simply this, ladies and gentlemen: This is a

serious case, the burden of proof is the same regardless of what kind of case it is. That is, whether it's a speeding case or a murder case,

theft, whatever, the burden is the same. Is there anyone, however, on the jury panel, because this is

a serious case, is there anyone who would require

me or the State of Alabama, that is, to prove to you beyond the standard which the Judge will explain to you, the defendant's guilt? Let me put it this

way -- and I accept your silence to mean that you wouldn't make me do more than I'm required to do by

Page 99


law.

Let's put it this way: Let's say we

could convert guilt into pounds or the burden of proof on the State, rather, into pounds.   Let's say what I had to do to prove to you all that this defendant is guilty is bring in here a wheelbarrow full of guilt -- that's my burden. And in that wheelbarrow the Judge says, "If he brings in ten pounds, then he has met his burden. And if he

brings in ten pounds and you are convinced there is ten pounds there, then that would be for the jury to decide, then your duty, your obligation, would be

to return a conviction.

Now, is there anybody on the panel that

to be more than certain in your own mind would require me to bring in 11 pounds or 20 pounds or ten pounds and one ounce?

(No response.)

MR. FRY: Judge Younger, do you want us

to do our death qualification at this point in the panel also?

THE COURT: Sure.

MR. FRY:  Yes, sir.  Bear with me, folks. This is probably some of the most important

Page 100


questions that I'm going to ask you coming up right here. And I'm going to ask, as so many of you have already been, for you to be very honest and very candid with me, because what we are going to be talking about now -- and I hope you will talk with

me -- is life and death itself .

This is a capital case, and because it's

a capital case it's different from any other case, criminal case, in the state of Alabama.    This is a case where if the defendant is found guilty there are only two possible sentences.   one is life in the penitentiary without the possibility of parole.

The other is death by electrocution in the electric chair.  Only two possibilities.   It's different, also, in that the process of the trial works a

little different from other trials, in that in a capital case the jury has to go a stage beyond what you all would do in any other kind of a criminal case, anything other than capital murder.    Any

other case, other than capital murder, the jury decides either the guilt or the innocence of the defendant and they go home.   And the Judge then decides what the sentence is going to be. There is an extra step in capital murder cases.   And that is,

Page 101


after the jury. returns a verdict of guilt in a capital murder case, then that jury is required to consider a sentence and to render an advisory verdict to the Judge. After that the Judge discharges the jury and at a later hearing the

Judge himself actually sentences the defendant.

But the advisory verdict is very important, very serious .In other words, in this case, if this defendant is found guilty, the 12 people remaining on the jury, after returning a verdict of guilty, will have to render an advisory verdict to Judge Younger as to what the sentence should be, either death or life in the penitentiary without the possibility of parole. Based on these facts, I

want to ask you a few questions.

Is there anyone on the panel who has ever written an article or a report or signed your name to anything in writing in regard to the death penalty? Reports, letters to the editor, correspondence with a friend. Mr. Curry?

A JUROR:  I have written a report in

school on capital punishment.

MR. FRY: All right. Was that in

undergraduate school or high school?

Page 102


A JUROR: High school.

MR. FRY: High school. All right.

That's Mr. Curry. Anybody else?

(No response.)

MR. FRY: Anyone else on the jury panel have you ever argued in favor or in opposition to

the death penalty, either in public or in private, either in a group which was informal or a group

which was formal? For instance, we have argued

about capital punishment in my Sunday School @lass. Maybe you have done the same thing.  Have any of you on this panel ever expressed an opinion publicly or privately to another person about the death

penalty? Mrs. Little, you have already done it a couple of times today, I think.  Outside of the courtroom?

A JUROR: Yes, among friends.

MR. FRY: Pardon me?

A JUROR: Among friends.

MR. FRY: Among friends.  Okay.  And in an informal discussion, then?

A JUROR: Yes.

MR. FRY: I saw another hand.  Yes,

ma'am.

Page 103

A JUROR:   I have in classes as well as among friends.

MR. FRY:   Classes and among friends.   And you are Mrs. Smith?

A JUROR:   Yes.

MR. FRY:   First name?

A JUROR:   R-o-b-i-n-a.

MR. FRY:   Yes, sir.

A JUROR:   James Wilkinson, informal among friends.

MR. FRY:   Mr. Wilkinson. Did I see another hand on the   right-hand side? Yes, ma'am.

A JUROR:   Among friends.

MR. FRY:   And your name? Mrs. Palmer?

A JUROR:   No, Painter.

MR. FRY:   Painter.  Yes, ma'am.

A JUROR:   Phyllis Cook, and I have talked among friends and coworkers.

MR. FRY: Mrs. Cook.

A JUROR: Yes.

MR. FRY: Yes,   sir.

A JUROR: Tom Floyd.    I'm sure I have discussed it at times, but I don't remember

anything specific, among friends.

Page 104

MR. FRY: All right, sir. Yes, sir.

A JUROR: Among friends.

MR. FRY:   Yes, sir.  Your name, please,

s i r ?

A JUROR:   Norman Houben.

MR. FRY:   Mr. Houben. Sorry, Mr. Houben. Did I see another hand in the back? Okay, on the left-hand side.   Yes, ma'am.

A JUROR: Lueguster Robinson, among friends and family.

MR. FRY:   Mrs. Robinson. And Mr. Latham. A JUROR:   Yes, among family and friends. MR. FRY:   Family and friends.   Yes, sir.

A JUROR:   Among family and friends.

MR. FRY:   And your name?

A JUROR:   Sammy Bartlett.

MR. FRY:   Yes, sir.

A JUROR:   Family, friends, and coworkers. MR. FRY:   And your name?

A JUROR:   Atteberry.

MR. FRY:   I'm sorry. Atteberry.    Yes, sir, right here.

A JUROR: Butler Hine.    I'm sure I have discussed it sometime, but I don't remember

Page 105

 

specifics

MR. FRY:  Mr. Hine.

A JUROR:  Yes, sir.

MR. FRY:  The gentleman back on my left.

A JUROR:  Poole. Among friends.

MR. FRY:  Mr. Poole. Yes, ma'am.

A JUROR:  Catherine Richardson.    I have discussed   it with friends.

MR. FRY:  Catherine Richardson?

A JUROR:  Yes, sir.

MR. FRY:  on this end.

A JUROR:  Kellie Rowe. Among friends.

MR. FRY:  Thank you, Mrs. Rowe.   Directly behind you.

A JUROR:  Stephanie Turner. In class and at home.

MR. FRY:  Mrs. Turner. All right.

Trying to keep them  in order. Yes, sir.

A JUROR:  Informally among friends.

MR. FRY:  Okay. Mrs. Yourick.

A JUROR:  In Sunday School and with friends.

MR. FRY:  Yes, ma'am.

A JUROR:  Bernice Ford, with family

Page 106

members.

MR. FRY: Yes, sir.

A JUROR:  Herbert Bruce.

MR. FRY:  Yes, sir.

A JUROR:  Deerman.   Among friends.

MR. FRY:  Mr. Deerman.   The lady behind you.

A JUROR: Judy Lamon.    I'm sure at some point I have discussed it.

MR. FRY: All right. Do any of you belong to any group, association, whether it be religious, civic, or otherwise, that has an official policy or an official philosophy in regard to capital punishment? Any group, any church, religious organization that, as far as you know, has a policy one way or another?

(No response.)

MR. FRY:  Have any of you on the jury

panel ever belonged to or contributed to an organization by the name of Amnesty International?

(No response.)

MR. FRY: Okay.   I have told you that the law in this state for this crime is, the only two alternatives for this punishment, for this crime,

Page 107

 

 

is either death or life without the possibility of

paro1e. My next question is not intended to challenge anyone's beliefs, to diminish your right as a citizen under the Constitution of the Federal Government or the State to express your beliefs,

but I merely have to ask you about your beliefs and what you choose as individuals to believe about the death penalty.  And you understand that that is an authorized punishment in the state of Alabama.

Please raise your hand if you are opposed to the death penalty as a form of punishment.   Ms. Little, we have already got yours down. Thank you. Mrs. Robinson, you are personally opposed to it as

a form of punishment?

A JUROR: Yes.

MR. FRY: Are there others?

(No response.)

MR. FRY:  This kind of gets into your religion and your personal beliefs, I guess.     It's not something we always want to talk about with a room full of strangers, but I really need to know this, this is serious.   Mrs. Robinson and Ms.

Little, do you believe there is no place in society for capital punishment? Ms. Little?

Page 108

A JUROR:  I wouldn't say that there is no place, but I haven't made a decision.    So if I haven't made a decision, it's no right now.

MR. FRY:  You would answer that as far as you know there is no place?

A JUROR:  Right. Right now.

MR. FRY:  Mrs. Robinson, how about you?

A JUROR:  I feel the same way.   I don't really know that there is a place.

MR. FRY: You can't perceive, you can't,

in your mind, see a place for it?

A JUROR: Right.

MR. FRY:  Okay.   The rest of you, let me ask you this question -- and I'm almost through, so bear with me.  I'm going to ask you a multiple

choice question. Let me explain it to you, then I'm going to give you an A, B, and C answer, and hopefully everybody will fall in either A, B, or C. If this works, you should. Assume that you have

been chosen as a juror on a capital murder case. After hearing all of the evidence and the law as explained to you by the Judge, you are convinced under the law that the defendant is guilty as

charged of capital murder.    Now, the Judge has told

Page 109

you that you must render an advisory verdict and

that there are only two choices, life imprisonment without the possibility of parole or death.   Now,

I'm going to read A, B, and C.  You should decide which one of these would apply to you.   Okay.  Don't answer.  I'm going to read them to you first, then I'll go back and let you answer in just a minute.

Based on these facts, which would apply

to you.  A:  I would consider voting on the death penalty.  B:  I might consider voting on the death penalty. And, finally, C: I would not vote, would not consider to vote, on the death penalty as a sentence. Okay.   Is everybody with me? All right. You know, you decided the defendant is guilty, you have got to make a decision, there are three

choices. Would you consider the death penalty, you might consider the death penalty, or you absolutely would not? First, let me see the hands, if I may,

of those of you who would consider the death

penalty as a sentence, that's answer No. A.

Okay. Thank you very much. Answer No.

B, I might consider death as a sentence.    All right. And I would like to get these names, if I may.    Mrs. Burns. Mrs. Carpenter.    Mr. --

Page 110

 

A JUROR: Collins.

MR. TRY:  Mr. Collins.   Yes.. sir.

A JUROR:  Cowley.

MR. FRY:  Cowley.   Yes, sir.

A JUROR:  Anthony Fair.

MR. FRY:  In back, back here.

A JUROR:  Kell.

MR. FRY:  Mr. Kell.   Yes, ma'am.

A JUROR:  McCalpine.

MR. FRY:  McCalpine.   Spencer.   Going on down.  Yes, sir.

A JUROR:  Walter Simons.

MR. FRY:  Simons.   Yes, ma'am.

A JUROR:  Rachel Ruddock.

MR. FRY:  Mrs. Ruddock.   In back. Mr. Wilson.

A JUROR: Wilson.

MR. FRY: James Wilson.    And Mr. Wilkinson.  All right, anybody else on this side? okay.  On this side.   Mr. Latham, Mr.

A JUROR:  Deerman.

MR. FRY:  Deerman.   And Mr.

A JUROR:  Curry.

MR. FRY:  -- Curry.

Page 111

 

A JUROR: Hall.

MR. FRY:  Mrs. Hall.  What is your first name, Mrs. Hall?

A JUROR:  Mavis.

MR. FRY:  Thank you.  Yes, ma'am.

A JUROR:  Nanette Davis.

MR. FRY:  Nanette Davis.   Yes, ma'am.

A JUROR:  Judy Lamon.

MR. FRY:  Lamon.  Yes, ma'am.

A JUROR:  Mrs. Kizziah

MR. FRY:  Kizziah. Pardon me for

pointing. My mother would kill me. That's the only way I know  to do it.

A JUROR:  Vera Mills.

MR. FRY:  Mrs. Mills.   Behind you.

A JUROR:  Catherine Richardson.

MR. FRY:  Catherine Richardson.    Behind you.

A JUROR:  Bernice Stewart.

MR. FRY:  Mrs. Stewart.   Mrs. Yourick in the back.   And I finally have a hand from this lady.

A JUROR: Sylvia Springer.

A JUROR: Celia Polke.

MR. FRY: Both of you, Sylvia Springer

Page 112

 

and --

A JUROR: Polke.

MR. FRY:   Mrs. Polke.

A JUROR:   Yes.

MR. FRY:   Yes, sir.

A JUROR:   Morgan Tunstall.

MR. FRY:   Dr. Tunstall.  Okay, that's the A's and B's.   Now, the C’s:  I would not consider

the death penalty as a sentence under any circumstance.   Okay.  Mrs. Little.   Did I see your hand? Your name, please, ma'am?

A JUROR: Robina Smith.

MR. FRY: Ms. Robina Smith. Again, Mrs. Robinson.

A JUROR: Yes.

MR. FRY:   Okay.  Now, be honest with me. Did everybody answer? Yes, sir.

A JUROR:   Henry Patton.   I think your question is a little general and I would sort of have to look at the case on its own.

MR. FRY:   Okay.  Well, I was just

assuming that whatever the case was you had decided that the defendant was guilty, but still you

would -- you wouldn't be able to base that without

Page 113

the full facts of the case? okay.   That's Mr. Patton?

A JUROR: Yes, sir.

MR. FRY: Thank you, Mr. Patton.   Anybody e1se ?Is there anybody else that felt like they couldn't answer the question?

(No response.)

MR. FRY: Just really one last thing.

The jury that hears this case, my understanding is, is going to be sequestered.  You might have guessed that or expected that.  It means that once the trial begins the jury is going to be held together, eat together, stay in a motel, be put to more inconvenience, frankly, than most juries would. Again, it's a part of the service, I guess, we have to give as citizens.  Is there anyone on the panel, now that I have told you about that -- I hope I didn't shock you or surprise you -- but is there anyone on the panel, now that you know that, that

has some kind of hardship which would render it difficult, if not almost impossible, for you to serve on this jury? Maybe people sick, maybe you have got a relative that's sick, you have got a

young baby, maybe for some reason or another the

Page 114

 

prospect of being isolated away from home and

family for some time would just work a very difficult hardship upon you.    I saw one hand -- several hands.    okay. It's just a matter of timing, I guess.   Yes, sir.

A JUROR:   I have a grandson that has leukemia and I have   a brother that has cancer.

MR. FRY:   And I'm sorry, forgive me.

Your name?

A JUROR:   James Collins.

MR. FRY:   Okay. Yes, sir.

A JUROR:   Depends on the length of time. MR. FRY:   I wish I knew. More than a

couple of  days.

A JUROR:   I mean, are you talking about more than  a couple of weeks?

MR. FRY: I hope not.

A JUROR:   I'm embarrassed to even say this, but I work several different places.

MR. FRY:   I noticed that.

A JUROR:   The only problem that I have is economics.   I mean, it would shorten my workweek a lot.

MR. FRY:   That's a problem most of us

Page 115

 

have.

A JUROR:  Yes   That's why I said I was embarrassed to say it, because all of us have those problems.

MR. FRY: Your name?

A JUROR: Aleen Costes. Laura is the way it's listed.

MR. FRY:  Okay.  On the right-hand side. Yes.

A JUROR: Robina Smith.    I'm a student

and I can be away for a week, but probably no more. MR. FRY:  Can't miss tests, can't miss

class and all that.   Yes, ma'am.

A JUROR:  Leigh Ann Locascio.    I have a one-year-old child.   It's not impossible, but my husband is self-employed.

MR. FRY:  Do you have a babysitter?

A JUROR:  I have day care.   It would just be pretty tough on my husband, not impossible.

MR. FRY: Your husband may be -mad at us before this week is over.   Yes, ma'am, you had your hand up first.

A JUROR:  Physical reasons.

MR. FRY: Okay.

Page 116

A JUROR:   Necessity to be --

MR. FRY:   That's fine.  That's fine.

other hands on the right-hand side.    Mrs. Little.

A JUROR:   I'll be honest.  It's not a medical reason, but it's just I have a meeting at

church that I have to be there.

MR. FRY:   You have to be there?

A JUROR:   I just have to be there.

MR. FRY: You know, I   have been ugly to

you all.  I have been going from this side to this. Yes, sir.

A JUROR:   I have a limit of about a week. MR. FRY:   Mr. Brett?

A JUROR:   Right.

MR. FRY:   Mr. Brett, what do you do at the university, by the way?

A JUROR:   I'm with the College of Engineering, and I'm with the Bureau of Engineering Research.   I have a number of critical projects

that are at critical stages right now.

MR. FRY: Are you in instruction or --

A JUROR:   Just research.

MR. FRY:   Just research?

A JUROR:   Right.

Page 117

 

MR. FRY:   Thank you very much.   Yes, sir.

A JUROR:   My wife does not drive an automobile for health reasons, and she depends on

me to go to the grocery store and run any errands . MR. FRY:   Mr. Curry?

A JUROR: Yes, sir.

MR. FRY:   Yes, ma'am.

A JUROR:   Wendy Mills. I have a four- month-old  child.

MR. FRY:   Four months old.

A JUROR:   That's a good reason.

MR. FRY:   It certainly is.   Mrs.

Robinson.

A JUROR:   I have two teenage daughters

and my husband is deceased.    one of my sons is in

the Army and the other one is married and lives out of the county.

MR. FRY:   You have got two teenagers home by themselves?

A JUROR:   Yes.

MR. FRY:   We might just ought to let you go right now. Mrs. Mills, the other Mrs. Mills.

A JUROR:   Husband is a diabetic. He is kind of slow about fixing food and I have got to get

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after him.

MR. FRY: Yes, ma'am.   He wants to be eating sweets while  you are gone?

A JUROR:  Yeah, he will.

MR. FRY:  This lady back here.

A JUROR:  Celia Polke.   My husband is

kind of ill and I have to take the child to school

in the mornings.

MR. FRY:  Mrs. Polke?

A JUROR: Right.

MR. FRY:  I don't mean to pry, Mrs.

Polke, but would your child have another way to school, could arrangements be made if you were delayed, if you were on the jury?

A JUROR: Well, I don't know.

MR. FRY:  I'm putting you on the spot. Would it be a hardship to you?

A JUROR: Well, he really don't have another way.

MR. FRY:  Then that would certainly be a hardship.   Yes, ma'am.  You are saying this child is dependent upon you?

A JUROR: Yes, sir.

MR. FRY: Okay. That is all I needed to

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know.  And I appreciate your honesty.     The lady behind you, did you have your hand up also?     No?

All right.   Anybody else?

A JUROR:   I do.

MR. FRY:   Yes, sir, Mr. Hitt.

A JUROR:   My mother and father is in

their 90s, and a lot of times they call me at night with bathroom problems or a pilot light out. I sometimes have to go over there during the night. And I'm a diabetic, also. I have to have a lot of medication.

MR. FRY:   Yes, sir.  Anybody else?

(No response.)

MR. FRY:   Ladies and gentlemen, I look forward to working with whoever is chosen for this

j u r y .I'll be living with you here in Tuscaloosa. Those of you that get stuck in a motel, I am, too.

So don't feel bad.  Maybe time will go by quickly

and maybe something meaningful will happen to all

of us.

Thank you very much for your patience and your consideration.

THE COURT:  Ladies and gentlemen, we are going to take a ten-minute recess, but before we

Page 120

do -- so let me instruct you not to discuss this

case with anyone, permit no one to discuss it with you or in your presence.   Now, ten minutes is not long.  So take a quick break.   Get some water or go to the restroom, and be back in your seats in ten minutes.   And, again, do not discuss the case with anyone or permit anyone to discuss it with you or in your presence.   Take a break.

(Whereupon, proceedings were in recess at 2:35 p.m., until 2:50 p.m., at which time the' following occurred:)

THE COURT:  Mr. Drake, you ready?

MR. DRAKE:  Yes, sir.

(Whereupon, Mr. Drake conducted a voir dire examination of the jury venire as follows:)

MR. DRAKE:  Ladies and gentlemen, as you know by now, I'm Jack Drake.   We appreciate your cooperation and patience.    We presented to you a questionnaire designed to speed this process up,

and I think it's going to work that way. And I particularly appreciate the fact that you took some care and time in answering the questionnaire.

You have met us all.   Marc Sandlin and Charlie Hooper are from Huntsville.    Bobby Lee Cook

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is from Summerville, Georgia.  And just so you will have some frame of reference there, Summerville is ten mile east of Mentone, Alabama, and about 80 miles away from Huntsville.  We represent Betty Woods Wilson, who is seated here, charged with capital murder.  Stand up, Betty, and let everybody look at you. And we are happy to be her counsel in this proceeding.

I have a few questions and I'll try to make them very specific and utilize the questionnaire, as best I can. We have not had much time to look at the questionnaire, but we hurriedly did that during the break, while we were trying to eat and look at the questionnaires at the same time.

The very last question on the questionnaire is No. 54, says, "Do you think, based on what you have read or heard, that Betty Woods Wilson is probably guilty as charged?"  Some of you answered that question, "Yes." And I take it that when you answered "Yes," that you meant by that answer that you would require some additional evidence from the defendant in order to change your opinion. Now, if you did not mean that when you

Page 122

 

 

checked "Yes," let me know right now.

(No response.)

MR. DRAKE:  Thank you. We asked on the questionnaire about your experience with the

justice system, we asked about civil cases and criminal cases, both.   We did not ask a couple of questions.  One of them is:   Have any of you ever served as foreman of a grand jury?

(No response.)

MR. DRAKE:  Any of you ever served as foreman or foreperson on a criminal jury As opposed to a grand jury, but a jury hearing a criminal case?

(No response.)

MR. DRAKE:  Some of you have indicated on your questionnaire that you have heard about this case, some of you have been fairly specific.    And

let me supplement some of those inquiries.    Have

any of you ever been in Huntsville and read the newspaper or heard a television report while you were in Huntsville about this case?   Is it Mr. Porter?

A JUROR: Yes.

MR. DRAKE: You already said you had seen the Huntsville Times or News, one of the two.

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Anybody else?

(No response.)

MR. DRAKE:  Have any of you discussed

this case with somebody who lives in Huntsville, friend, relative, somebody you used to work with that got transferred up there, anybody who lives in the Huntsville area? And let me sort of expand on that, too, because, you know, North Alabama is all kind of right together, it's not exactly like it is here in West Alabama.   And when I say the Huntsville area, I'm really talking about Huntsville and Florence, Tuscumbia, Sheffield, Arab, Cullman, all of that whole area.   Decatur.   Have you talked with anybody that lives up in there about this case?

Yes, ma'am.

A JUROR:   I spoke with my sister who

lives in Madison.

MR. DRAKE:   Yeah, Madison is just

basically a part of Huntsville.    It's sort of a suburb.   I mean, it's not quite like being from Northport, but it's pretty close. They have kind

of grown together.

A JUROR: Right.

MR. DRAKE: All right.     Anybody else in

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that area, ta1ked with anybody in that area?

(No response.)

MR. DRAKE: some of you indicated in your responses on the questionnaire -- and, again, we

had to do this hurriedly, so I may not be totally

100 percent correct about this -- but some of you indicated some relationship with the deceased, Dr. Jack Wilson, either you had been treated by him or somebody in your family had been treated by him.  He was an ophthalmologist.  Seems like somebody wrote down on one questionnaire, I remember seeing that

he operated on my sister or brother or something

like that.  Your sister in Madison?

A JUROR: Right.

MR. DRAKE: You need to say your name for the record every time.

A JUROR: Rachel Ruddock.

MR. DRAKE: Okay. Anybody else that's ever been treated by Dr. Wilson or had a friend or family member treated by him?

(No response.)

MR. DRAKE: Mr. Fry asked you about some legal principles, and I'm going to ask you some similar questions as to the ones that he asked.  He

Page 125

partly explained to you that Betty Woods Wilson is presumed to be innocent of the charge against her, and some of you wrote that down on the

questionnaire in answer, you said, "She is presumed to be innocent." That's called the presumption of innocence.  It attached when she was indicted.    it

is with her today and goes with her until the end of the trial. Now, is there anybody here who doesn't either understand that or doesn't believe that?

(No response.)

MR. DRAKE: He mentioned the State's burden of proof.  The State has to prove its charge here beyond a reasonable doubt. And what I have

said all my life is a reasonable doubt is a doubt that's based on a reason as opposed to something

you might think up or some bias or whatever on your part.  And is there anyone here who does not understand or accept that the State has that burden to prove its case beyond a reasonable doubt?

(No response.)

MR. DRAKE: This case comes to you on the basis of an indictment, which is -- and the Judge at some point will tell you this -- it's simply a means of initiating these proceedings.   It's not in and

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of itself evidence of anything.  And is there anybody here who doesn't understand that to be the case, that is, that an indictment is not evidence

of guilt? We all understand that, all accept that?

                 (No response.)

MR. DRAKE:  I want to talk to you about some people that we think will testify in this

case.  And some of Dr. Wilson's family members are here in the courtroom, and a great many of Betty's family are seated over here, her mother and her children and sister and other relatives in her family.  Some of them nay testify, depends on what happens in the case. Some of the members of Dr. Wilson's family are seated over in the jury box,

and some of them may testify. And I would like to ask if any of you know any of them, and if you don't mind I would like for you, 'when I call your name, to stand just briefly.  Stephen Wilson.  And Stephen,

I understand, lived in Tuscaloosa for a period of time; is that right?

MR. WILSON: Yes.

MR. DRAKE: And Scott Wilson.   There in the red tie. And then Perry Wilson.   Do you know

any of those three men?

Page 127

(No response.)

MR. DRAKE: Now, Mr. Fry introduced members of his team, if you want to call it that,

his people who are working with him. Do you know

any of those people?

(No response.)

MR. DRAKE: Now, I understand, Mr. Fry, that this lady is a sister of Dr. Wilson?

MR. FRY: Jane English.

MR. DRAKE: Jane English, who is a

sister. Mrs. English, where do you live?

MRS. ENGLISH: Tennessee.  Knoxville, Tennessee.

MR. DRAKE: Okay. Knoxville. Does that ring a bell with anybody?

(No response.)

MR. DRAKE: You were introduced to Detective Micky Brantley of the Huntsville Police Department, and he will be a witness.  You have been asked if you know him.  There are three other police officers, at least, if not more, from Huntsville. Bill Payne, Glenn Hunley, and Harry Renfroe. Do

any of those people -- ever had any dealings with them?

Page 128

 

(No response.)

MR. DRAKE:  There are some other people who will be witnesses, too, a Russell Hughes in Vincent, Alabama.   Any of you know Mr. Hughes?

(No response.)

MR. DRAKE:  or Jeanne Ogle, Sylacauga, Alabama, might be a witness.

(No response.)

MR. DRAKE:  Brenda Cerha, who lives in Huntsville, was or is a registered nurse.    Does anybody know her?

(No response.)

MR. DRAKE:  On the questionnaire we asked if any of you knew a man by the name of James D. White.  And I have not had a chance to look at any

of those answers, and I'm sorry, we will do that tonight, but let me ask some more specific

questions about him.   He is the man who killed Dr. Wilson, and the State has entered into something called a conditional plea agreement with him, in which the State says that it cannot prove its case without his testimony.   They have admitted that.

So I want to know any possible connection or knowledge of this man that they built this case

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around.  Now, he has not always been known as James D. White.  He was once known as James D. Howell .   In fact, that's what his name is, but his -- and his military records and his official records that we all have compiled are basically under that name. Anybody ever know a guy named James D. Howell?

(No response.)

MR. DRAKE:   He went to high school in Sylacauga, I believe it was, and he was known then

as Dennis Howell.   He was there, as I calculated, in the mid 1960s, and dropped out of school in the

tenth grade and went in the Army.    Does that help ring a bell about anything about him?

(No response.)

MR. DRAKE:   Quite a few of you -- yes, ma’am.

A JUROR:   Excuse me, sir.  My name is

Gayla Walker.   You had this question on this questionnaire and I'm not sure whether I checked it "Yes" or "No." I just wanted you to know that.

MR. DRAKE:   That's fine.   Some people didn't.   That's fine.

Let me continue on about James D. White

or James D. Howell.   He has been known as James B.

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White, Bob White, Cookie.  Those are the names that

I know about.

(No response.)

MR. DRAKE:  Some of you here work at the

VA Hospital

THE COURT:  Just hold up.

(Brief pause.)

MR. DRAKE:  Should I continue?

THE COURT: No.   I tell you what: You gentlemen come back up here and let's make a

decision on where to go.

(Brief pause.)

(Whereupon, the following occurred at the bench, out of the hearing of the jury venire:)

THE COURT:  No. 37, Julia Horton, excused herself from the panel, and the information is that she is sick.  Mr. Drake, you want the Court to wait or --

MR. DRAKE: No, we want to proceed. We will agree to have her excused.

THE COURT:  Mr. Fry, what's the State's position?

MR. FRY:  The state is satisfied to let her be excused.  No objection.

Page 131

THE COURT:  No. 37 will be excused.   Mr. Drake, you may continue.

(Whereupon, Mr. Drake continued to

conduct a voir dire examination of the jury venire

as follows:)

MR. DRAKE:  Ladies and gentlemen, we were talking about James D. White, James D. Howell. He has been a patient at the psychiatric unit of the VA Hospital here several times, and I wonder if any of you who have worked there or had family members who worked there might have had any kind of contact

with him.

(No response.)

MR. DRAKE:  He has been treated for psychiatric problems at Brookwood Hospital in Birmingham, at the VA Hospital in Murfreesboro, Tennessee, and, again, I wonder if that jogs any kind of memory you might have about whether you

know him or not.

(No response.)

MR. DRAKE:  We ask on the questionnaire about those of you who served in the military.    we did not ask about types of discharges.    Is there anybody on the panel who served in the military who

Page 132

got anything other than an honorable discharge?

(No response.)

MR. DRAKE:  Finally, about this man James D. White:  He has been married four times.   I have tried to find out the names of his ex-wives to see

if any of you might know an ex-wife, and I haven't been very successful.  But one of them is named Cheryl Frost, and she has lived in the Vincent, Alabama, area., at least at one time., if not now.

Any of you have any knowledge of her?

(No response.)

MR. DRAKE: And one of his ex-wives was named Mary.  I don't know if it was Mary Howell or Mary White.  Does that ring a bell with anybody?

(No response.)

MR. DRAKE:  okay.  In this case there is going to be evidence that Dr. Wilson and Betty

Wilson had an unusual marriage.   There will be evidence that Betty had a couple of affairs during the time that she was married to  Dr. Wilson.  I want to lay that out for everybody so that you know now that that evidence will come in.   Of course, she is not charged with that kind of conduct, but I need to know if there is anybody on this panel who would

Page 133

 

hold that kind of conduct against her and would

not, for example, believe her if she testifies in the case, would tend to disbelieve what she said because she had had an affair while being married. Would it affect any of you that way? Would it

affect any of you to the extent that you could not give her a fair trial?

(No response.)

MR. DRAKE: And, again, there is another

aspect to it that I have got to just tell you about, and we have to do this, and I would appreciate your honesty if it makes any difference to you. There will be some evidence that she had an affair with a black man, and I need to know, again, if that would affect any of you and affect your ability, for example, to believe her. Would you tend to discount what she says because she had done that?

   (No response.)

MR. DRAKE:  Would it affect your ability

to give her a fair trial?

(No response.)

MR. DRAKE:  Betty is also an alcoholic.

I don't mean she drinks, because once you are an alcoholic you are always one, if you know anything

Page 134

 

 

about the disease.  She is a recovering alcoholic,

quit drinking in December 1986, and has been extremely active in Alcoholics Anonymous since that time, often going to as many as three AA meetings a day in Huntsville. But would the fact that Betty is an alcoholic and has had a history of abusing

alcohol or even of being addicted to alcohol, would that affect your ability, again as an example, to believe her? Would you think less of her and tend not to believe what she tells you or would it' affect, in any way, your ability to give her a fair trial?

(No response.)

MR. -DRAKE: Do any of you know any

medical doctor in the Huntsville area, any physician?

(No response.)

MR. DRAKE: Any of you know a registered nurse or an LPN in the Huntsville area? Oh, I'm sorry, I didn't see your hand.

A JUROR: I'm Leigh Ann Locascio.   I was in the National Guard in -- with --

MR. DRAKE: Would you stand up. We can't hear.

Page 135

 

A JUROR:  I was in the medical National Guard and our sister unit was in Huntsville, there was quite a few nurses.   I'm not -- you know, I

don't correspond with them now.

MR. DRAKE: Have you seen any of them in the last 18 months?

A JUROR: Not in the last year.

MR. DRAKE: You talked to any of them about this case?

A JUROR: No.

MR. DRAKE:  And a hand back here, too.

Yes, Mr. Porter.

A JUROR:  I have a daughter-in-law that's an RN.

MR. DRAKE:  In Huntsville?

A JUROR: Yeah.

MR. DRAKE: Where does she work?

A JUROR: Works for the --

MR. DRAKE: For what?

A JUROR:  Human Services.

MR. DRAKE: For what?

A JUROR:  Human services.    She goes to

the houses and works with older people.

MR. DRAKE:  one of these home health care

Page 136

agencies, that kind of thing?

A JUROR: Yeah.

MR. DRAKE: What's her name?

A JUROR:  Susan Porter.

MR. DRAKE:  Susan Porter.  Do you know if she knew Dr. Jack Wilson?

A JUROR: Not to my knowledge.

MR. DRAKE: Okay.   Did she ever work at one of the hospitals there?

A JUROR:  No, she has been in there ever since she has been up there.

MR. DRAKE: Anybody else?

(No response.)

MR. DRAKE: Mr. Fry has introduced

himself and you have been asked some questions

about him. Do any of you know Jimmy Fry from

Athens? Have any of you ever lived in Athens? Yes, sir.

A JUROR: Until I was one year old.

MR. DRAKE:  I don't think that hardly counts.  I appreciate the answer, Col. Hine.

Anybody else who lived there at any time, anybody have any family up in that area, Limestone County? Yes, ma'am.

Page 137

A JUROR:  I have an uncle who lives in Huntsville.

MR. DRAKE:   Your name?

A JUROR:   Donna Johnston.

MR. DRAKE:   Okay.   Yes.   Stand up.

A JUROR:   I have an aunt -- I mean, not an aunt, a cousin that lives there.      They just moved up there about two months ago.

MR. DRAKE: Who is that?

A JUROR: Pat Woodard.

MR. DRAKE: Pat Woodard?

A JUROR: Yes.

MR. DRAKE:    Is that a woman?

A JUROR: Yes.

MR. DRAKE: Female?

A JUROR: Yes.

MR. DRAKE: Have you talked with her

about this case at all?

A JUROR: No.

MR. DRAKE: Okay. Thank you. Anybody else?   Yes.

A JUROR:   I have a niece that lives in Decatur-Huntsville area.

MR. DRAKE: Okay. Let's start with your

Page 138

name.

A JUROR: Eleanor Ewing.

MR. DRAKE: Mrs. Ewing. And who is your niece?

A JUROR: Rita Kent.

MR. DRAKE: Rita Kent. All right.

Anybody else there? Yes, sir.

A JUROR:  Henry Patton. My father-in- law, Boswell Howell.

MR. DRAKE: Where does he live?

A JUROR: Huntsville.

MR. DRAKE: Mr. Ford.

A JUROR:  I have an uncle, Frank Ford, that lives in Huntsville, and his daughter, Shelly Kaufmann, and her husband, Ernest Kaufmann, which are my cousins.

MR. DRAKE: Have you talked to them about this case?

A JUROR:  No, I haven't.

MR. DRAKE: Anybody else? Yes.

A JUROR: My sister.

MR. DRAKE: You have told us about your sister that lives in Madison. Yeah, Mr. Porter,

you have told us --

Page 139

 

A JUROR:  I also got a daughter up there,

too.

MR. DRAKE:  Okay.   What's her name?

A JUROR:  Laceys Spring.   Hall.   Shirley

Hall.

MR. DRAKE:  Have you talked to her about

this?

A JUROR: No.

MR. DRAKE: Anybody else?

(No response.)

MR. DRAKE: Okay. Mr. Fry did not introduce Tommy Smith over here at the end of the jury box, who is with the Tuscaloosa District Attorney's staff , and he is assisting in some way

in this case.   Do any of you know Tommy? Mrs. Holland?

A JUROR:   I know Tommy.

MR. DRAKE: Okay. Would the fact that Tommy is involved in this have anything to do with the way you would view the case?

A JUROR: No, sir.

MR. DRAKE:   Anybody else that knows Tommy on a personal basis? He is sort of a public figure and I know that all of us know him in one way or the

Page 140

other, but I'm talking about if you know him to

speak to him and talk to him, that kind of thing.

(No response.)

MR. DRAKE: And Charlie Freeman was here earlier.  Do any of you have -- would any of you consider yourselves to be friends with Charlie Freeman? Mrs. Holland.   Anybody else?

A JUROR: I know his mother.

MR. DRAKE: I do, too.

A JUROR: Lovely lady.

MR. DRAKE: I want to ask you about a law firm called Sirote & Permutt. And a lot of times we read off the names of everybody in the law firm, but they have got about a hundred lawyers and I'm not going to do that.  They have offices in Birmingham, Mobile, Montgomery, Tuscaloosa, and Huntsville.

And they do estate planning work, tax work,

corporate work, business planning, civil

litigation, that kind of thing. And they have had

an office here, off and on, for years. And David Wooldridge, who is Bobby Wooldridge's brother, used to come down here and meet with people once a week.

I don't know if he still does it or not. But have any of you had any work done by Sirote & Permutt?

Page 141

They represent the Wilson children in some civil lawsuits pending in Huntsville, is the reason I'm asking the question.  Any of you ever had any work done by that law firm?

(No response.)

MR. DRAKE: Any of you ever had any relatives or friends who are employed by that law firm? They have several hundred employees.

(No response.)

MR. DRAKE: As Mr. Fry brought out, I

have been here a long time and I have been involved in a lot of legal matters, and I wonder if my firm has ever been on the opposite side of any of you in

a dispute, whether it went to court or not, whether we wrote letters to each other or had a meeting with lawyers, anything of that sort. Have we ever been

in an adversarial position with you or your business? Mr. Curry?

A JUROR: King Curry.  Somewhat of an adversarial situation with Mr. Pierce and one of

his clients, but we were able to work it out on the table.

MR. DRAKE: Good. Good. Anybody else?

(No response.)

Page 142

MR. DRAKE: And that would apply to me

and Joe Pierce. And we practiced law for a long

time with Ralph Knowles, who now lives in Atlanta.

If that would make any difference.   Ralph Knowles,

K-n-o-w-l-e-s.  Does that ring a bell with anybody?

(No response.)

MR. DRAKE:  I have got a specific

question for Robert Anthony Mann, if I can ask him

to stand. Mr. Mann, would you stand up? on your questionnaire we asked if the Judge told you that

you should not give any particular weight -- that's the wrong way -- ny more weight to a police

officer's testimony, would you follow those instructions, and you said no, you would not. Do

you think that a police officer's word is better

than a non-police officer?

A JUROR:  I was confused with the

question.

MR. DRAKE: Okay.    Let me ask it this way: Do you understand that every witness who takes that stand is entitled to the same treatment --

A JUROR: Right.

MR. DRAKE: -- by you if you are a juror, whether it Is a police officer or not? I mean, you

Page 143

can choose not to believe somebody, but you don't have any presumption or predisposition to take the word of a police officer over an average person, do you?

A JUROR: No, sir.

MR. DRAKE: Okay, thank you. Mr. Poole, you are a pharmacist, and I don't want you to tell

me what you know, but is it a part of a

pharmacist's -- I just need to know if you know this or not.  Are pharmacists trained to determine the

effect of the combination of the use by a person of alcohol and a narcotic like Darvocet? Would you

have some knowledge as to how that would affect a person's ability to reason or how a person might react to a given situation? Would that be

something within your field of expertise?

A JUROR:  Physically or psychologically? MR. DRAKE: Either.

A JUROR:  Physically, yes; not so much psychologically.

MR. DRAKE:  Okay, thank you.    I have

asked a lot of questions, and I think I'm about through here.   But is there any reason any of you

can think of why you should not serve on this jury?

Page 144

 

Is there any reason why you -- and you don't even have to tell me the reason, if there is a reason

why you can't be fair to Betty Woods Wilson and treat her just like you would anybody else?   I need to know that, need to know it right now.

(No response.)

MR. DRAKE: Thank you very much.

THE COURT: Mr. Fry, do you have any

other questions?

MR. FRY:  I have no further questions, Your Honor.

THE COURT: All right. Then, we are

going to take about a -- at this point we will take a 15-minute recess.  Same instructions given at the other break, ladies and gentlemen; do not discuss the case with anyone, permit no one to discuss it with you or in your presence.

And, Mr. Drake, if you and Mr. Fry and

the other lawyers will --

MR. DRAKE: Yes, okay.    I wanted to tell you about sort of a housekeeping thing.

THE COURT: Right. We are going to

want to meet with you during the recess, so we can do that, unless you needed to do it right now.

Page 145

MR. DRAKE: No, I was going to introduce this questionnaire into evidence.

THE COURT:  okay, ladies and gentlemen, take a 15-minute recess. And when you return,

please come back to the same seats that you are in,

if you can do that.

(Whereupon, the jury venire was recessed at 3:25 p.m., at which time the following occurred

in the Judge's chambers out of the presence and hearing of the jury venire:)

THE COURT:  Okay. Now, gentlemen, during the recess, let's take up any matters that need to

be taken up outside the presence of the jury.  You have, if I recall, 95 jurors.  And that means that with 14, which is the selection of two alternates, each of you have 40 strikes.

MR. DRAKE:  We have a lot of challenges

for cause.

THE COURT: Now, I was going to -- well, I don't see too many, but I see -- I don't know,

unless they come up on those questionnaires, but I was going to point out to you, Mr. Fry, that it

seems that in any situation that might be questionable, you certainly would not want to

Page 146

exercise a challenge for cause with that many strikes.

MR. FRY:  Noted and understood, Your Honor.

THE COURT: Let me point out to you that the juror that you inquired about, for your information Mrs. Turner stated that his conviction is for a misdemeanor.

MR. FRY:  I was misinformed., Your Honor. THE COURT: That information

(Brief pause.)

THE COURT: RSP3, 3rd.

MR. FRY: Yes, sir, I had that. I also

had RSP 2nd, but maybe -- looks about like the same time.  Maybe it was reduced or something.

THE COURT:  I have no way of knowing.

MR. FRY: Yes, sir. All I had was what I was told, Your Honor.

THE COURT: But if you don't want to pursue it --

MR. FRY:  There is no challenge.

THE COURT:  -- in the way of challenge, then it won't be necessary to talk to -- it won't be necessary to question that juror individually.

Page 147

 

MR. FRY: That will be unnecessary, Your Honor.

THE COURT:  All right.  Both of you are -- are both of you through, have you both completed your voir dire examination?

MR. DRAKE:  Yes.  I would like to get

these questionnaires marked and make them an exhibit. Do you want to make then a joint exhibit

or Defense Exhibit 1?

MR. FRY: Judge, I didn't get those' until 20 -minutes after 12:00. 1 haven't had a chance to look at them. All we could do was break then out into categories, basically. As long as what you

got, Jack, is the ones they turned back in, that's fine.

MR. DRAKE: That's it.

MR. FRY:  If all we are doing --

MR. DRAKE: Just putting them in. How do you want to mark them, joint exhibit or --

MR. COOK:  Let's mark them a joint exhibit, collective, Defendant's and State's exhibit, one court exhibit.

THE COURT:  It really would be a joint exhibit, not a court exhibit.

 

Page 148

MR. DRAKE: Judge --

THE COURT: Joint Exhibit No. 1, then, is admitted.

MR. DRAKE:  Your Honor, we have two other matters we want to take up.   One is that -- and I'll start right on the heel of these questionnaires.    A number of people answered question 54 "Yes," the question being, "Do you think, based on what you have read or heard, that Betty Woods Wilson is probably guilty as charged?"   In my voir direI followed up on that question by asking people that

I interpreted a "Yes" answer to mean --

THE COURT: All right. Now, Mr. Drake, let me tell you that I do not know what the answers were, because I haven't seen the questionnaires,

but whatever their answers were, you have a

right -- and I'll give you that right -- to ask

those questions individually.   But for you to proceed on the basis of their answers alone would not be sufficient, but you have the right and I'll give you the right to individually ask them when we go back out there about question 54.

MR. DRAKE: Okay.   Well, let me complete my thought first, if you don't -- I mean, I'm not

Page 149

 

arguing with you.

THE COURT: I know it.  I interrupted

you.  I saw what was coming.

MR. DRAKE: Okay.

THE COURT: And I may be wrong.

MR. DRAKE: All I was going to add was I followed that up with a voir dire question, that I interpreted that yes answer to mean that the defendant had to come forward with evidence to change their minds, which means the burden of proof changed.

THE COURT: Mr. Anthony Mann told you

that he had misunderstood the question.

MR. DRAKE: No, whole different question. That had to do with police officers.

THE COURT: He told you he had misunderstood the question insofar as it pertained to believing a police officer.  That may be the same with these people who answered that question in the way that you assert.  So you have a right to -- I'll give you the right to question them.

MR. FRY: May I interject, Your Honor?

on each of those. none of those people have had any law explained to them, they are like tabula rasa, a

Page 150

 

clear slate.  The questions I asked, I think I asked all of them, -based on what they knew could -they set aside whatever they knew, and the whole panel indicated, I think, maybe they could, maybe with

one or two exceptions, but that flies in the face of the response that Jack is trying to say his leading question elicited.  If they are going to be

challenged and excluded from the jury, they should have at least

THE COURT: That's what I just got

through telling him, Mr. Fry. He has the right to question them further, and you have a right to question them in response to their answer to that questionnaire, but at this time I would not be in a position to rule on your challenge, if you assert

one.  Now, we are not through.  The panel is coming back in in short order.

MR. DRAKE:  Yes, sir.  I'm challenging

them for cause.  You asked if we were through, and I said, "Yes," and I'm challenging these people for cause.

 THE COURT: I'm not going to grant your

challenge based upon their answer to that questionnaire, without more.  But I will give you

Page 151

the right to question each one of them in regard to their response --

MR. DRAKE: Can I --

THE COURT:  -- to question 54.

MR. DRAKE:  Can I question them individually outside the presence of the rest of

the venire?

THE COURT: How many you got?

MR. DRAKE: There is at least 30.

MR. SANDLIN: Yeah, around 30.

THE COURT:  I don't know that it would be necessary.

MR. DRAKE: Well, you see the dilemma I'm in.  I don't want them getting up and saying why they think she is guilty and poisoning the jury venire.

THE COURT:  I don't think you can assume that the people out there are going to be misunderstood and that they are dishonest.     You can explain it to them and further question them, and

if that stands as their answer after explanation, then I'll grant you the challenge.    I'll grant your challenge.

MR. DRAKE:  Well, I think we have

 

page 152

established what we wanted to in the record.  I do not want to question these people out in front of

the whole venire.

THE COURT:  Well, then, the only other recourse -- alternative, would be to let you question them individually.  I'm not willing to let that stand as a point of contention.

MR. DRAKE: All right. The other

matter -- may I tell you what we have been told,

then let's see where we go from there? We have been told by the Circuit Clerk that on Friday the presiding Judge of this circuit, Judge Conger, instructed the Clerk's Office to identify jurors by race and sex, and to provide that information to

the District Attorney's Office, which in turn used it to access NCIC computer information on the

entire jury panel.  We did not have that

information, and even if we had, we could not have accessed the NCIC computers. Now, we are

concerned, being put at a disadvantage.  I frankly wonder, you know, whether somebody has violated the law or not, because the next step, I'm told, is you get the people's Social Security number and put it in a computer and get information on them.  I don't

Page 153

know if you can do that or not.

THE COURT: Well, Mr. Drake, that was a different question than the one you are posing.

MR. DRAKE: Yeah, but we would like a disclosure from the District Attorney's Office.

And if we have to get the Tuscaloosa District Attorney's office in here to tell us what happened, then that's what we are requesting.  We want a disclosure of what was done, and if such

information has been made available to Mr. Fry,

then we want the same information.

THE COURT: Are you willing to give him your information? Don't you think he is entitled

to have to make -- to make investigation into the background and the information about jurors?

MR. DRAKE:  I'm concerned about him having information that he is not supposed to have, which I think is what we are talking about.

THE COURT:  Well, information that he is not supposed to have is one thing, but how it impacts on this case is another, and I don't see any.

MR. DRAKE:  Well, it's information

that --

 

Page 154

THE COURT: Well, hold on a minute.     Let

Mr. Fry respond to your --

MR. FRY:  Judge, what I have been given

is just a bit of history.  Charlie Freeman and his office here is having a week of court, also, this week, and they have gone through their preparation and their discovery, looking into the background of jurors for this week.

Now, Jack, if it's the way they always do it or if it's different, I don't know.   All I know

is I was given a jury list with remarks put on there by the District Attorney's staff.   Someone had -- was a good citizen or someone the District Attorney knew him to be a little different or watch this

one -- just the typical kinds of things you would get. Plus criminal information, where people have been arrested, which apparently would have come off of the NCIC.  Including people who had been

arrested for felonies, all of which apparently are no longer on the jury panel.   Most of them, I think, didn't show up this morning or they were never on the list. One or two of them that did show up, I think the Clerk said she excused.   But, Judge, that is all I have.  And I would have been happy to have

Page 155

 

provided -- not the personal information from the District Attorney.  I think that's work product.    I think I'm entitled to that -- but I would have been happy, if it had been requested, to provide

whatever the NCIC information was that was included in the list that I got.

MR. DRAKE:   But you,are saying the NCIC information applied to people that are not on this venire now?

MR. FRY:   No, I'm saying it applies*-- as applies to felonies, people are not on there now.

And other than that, I really don't know. There was some stuff on there for bad checks, there was stuff on there -- information about speeding cases.    And whether or not that was from NCIC or District Court records or from the Assistant District Attorney's personal knowledge, I don't know, I don't have case numbers or dates.  All I have got is a name and

three speeding cases or a name and convicted of carnal knowledge, that was one of them.    And that

guy didn't show up.

THE COURT: Mr. Fry, could you possibly make that information -- the information that you say you obtained, make it available to them? I'm

Page 156

not talking about work product, the information

that you obtained from NCIC.  If he is complaining about there being an unlevel playing field, make it available to him.

MR. FRY: I can give him what I have, Your Honor, not vouching for -- as you have already

seen, there was one case, apparently, that we were

in error about.  I don't mind giving him exactly

what I have as goes to criminal histories, bad checks, speeding or felonies.  And, as I say, I

don't think there is any more felons on the jury.

THE COURT: Mr. Drake, would that solve your problem?

MR. DRAKE: We would very much like to

have that information, and if there is no other information, then I guess it does solve our

problem.

THE COURT: Sure. Okay. Well, he says he can do that and that will solve the problem.

MR. FRY: Is that a problem?

MR. SMITH: Judge, I'm Tommy Smith with the District Attorney's office here in Tuscaloosa.

THE COURT: Right.

MR. SMITH: And I'm usually the one in

Page 157

 

charge of getting the background information for

the jury panel during jury weeks and did in this

c a s e .Some of what Mr. Drake said was not correct, but not necessarily needing to be a bone of contention. What he is talking about are driver histories and NCI reports that we routinely get within our office.  They are, in part, work

product, in that we make the effort to get the background information.  I'm not involving myself, certainly, in Mr. Fry's case, but it is, I believe,

a misdemeanor if anyone who is unauthorized should get access or be given those reports.  Mr. Fry is authorized as is the District Attorney's office, certainly. And we do not routinely give that as a matter of discovery for that reason.  It's not that we are necessarily trying to hide anything, but the law is the law.  And the Supreme Court of Alabama has, on occasion, addressed the issue, or at least once, and I'm sorry, I don't know the case name, but they have said it's not a matter of discovery, but

if it is used in challenging a particular juror or striking a juror, that certainly it would be appropriate for the Court to view in camera.  But

for our office, we are not objecting to Mr. Fry's

Page 158

making it available, but I think to comply with the requirements it would need to be an order as

opposed to an agreement.

MR. FRY:  I think so, Your Honor.   If you would order me to do that, I would be covered.    Be happy to do it, anyway.

THE COURT: Well, whether or not I do it in the absence of your agreement, is one thing, but otherwise, since you have agreed, then it is the order that you give that information to the defendant.  That satisfy you?

MR. DRAKE: Yes.

THE COURT: All right. Now, Mr. Drake, I don't have any way of knowing these numbers on

these jurors.

MR. DRAKE:  I can give you what they are and maybe I better do that to make it clear on the record. We would challenge the following jurors who answered yes to question No. 54:    Elizabeth Burns, No. 7.

THE COURT: Hold on. Give them to me. Elizabeth Burns, No. 7. All right.

MR. DRAKE: James Collins, No. 9.

THE COURT: All right.

Page 159

MR. DRAKE: Phyllis Cook, No. 10.    Laura Costes, No. 11.  Nanette Davis, No. 17.   Eleanor Ewing, No. 23.  Cuple Gann, G-a-n-n, No. 29.

THE COURT:  No. 29 is not on this list.   I mean, it's scratched out on mine.   29 on my list is scratched out.

MR. DRAKE: Well, I don't know what to

say about that, except that we have got a questionnaire on her, apparently.

THE COURT:  I don't know what happened to that juror.

MR. SMITH:  There were three that were excused this morning.

MR. DRAKE:  Maybe she was excused after filling out the questionnaire.

THE COURT:  I believe Mrs. Turner indicated that one may have gotten sick this

morning.

MR. DRAKE: Okay. The next one would be Margene Hinton, No. 34.

THE COURT: All right.

MR. DRAKE: Betty Holland, No. 36.

THE COURT: All right.

MR. FRY: Isn't she gone?

Page 160

 

MR. DRAKE: No.

THE COURT:   37 is off , 36 is Holland

okay.

MR. DRAKE:   No. 45, Mary Kizziah.    No.

48, Ervin Latham.

THE COURT:   Okay.

MR. DRAKE:   No. 52, Leigh Locascio.

THE COURT:   Okay.

MR. DRAKE:   No. 571 Terry McGarrah.

THE COURT:   57 is off.

MR. DRAKE:   okay.

THE COURT:   McGarah is off.

MR. COOK:   57 is off?

THE COURT:   On my list it's marked off. MR. DRAKE:   59, Diana Mills.   No. 62,

Elouise Montgomery.    No. 69, Guy Pate.   No. 73, William Porter.    No. 88, Watson Taylor, Jr.

THE COURT: which one?

MR. DRAKE:   88, Watson Taylor. 89, Doris Townsend.   97, Monica  Woods.  99, Dorothy Yourick.

THE COURT: okay. How many is that?

MS. ADCOCK:   19.

THE COURT:   19. Let me ask you this:

What about dividing them up into panels rather than

Page 161

one at a time?

MR- COOK:  I'm sorry, Judge?

THE COURT: You are going to be here

awhile if you want to take them one at a time. Why don't you divide them up and take about six or eight or ten in a panel , and we will send these to the assembly room and keep about --

MR. DRAKE: Just keep all of these people by themselves, maybe.

THE COURT: Well, we will send -- we will just take you about six, a panel of about six at a time.

MR. COOK: Haven't we -- isn't this the only issue that's outstanding, the voir dire issue with reference to this particular group?

THE COURT: There is one other I want to ask Mr. Fry about, and that is on his challenges for cause on the opposition to the death penalty.  I believe you would have to ask some more questions, but if you are not going to -- there were two or three.

MR. FRY: Two.

THE COURT:  If you don't exercise a challenge for cause, then it won't be necessary to

Page 162

 

 

go any further.

MR. FRY:  I think we have enough strikes, Your Honor.

THE COURT:   That's the reason I pointed

it out, I think you have got a lot of strikes.

MR. COOK:  Just purely a suggestion,

Judge Younger, but might I suggest that you excuse all of the other jurors for the day, other than this particular group?

THE COURT: Right.

MR. COOK:  That is involved in the immediate  problem, and see if it can be resolved that way.

MR. DRAKE:   I like that idea.

MR. SANDLIN:   I do, too.

MR. COOK:  Then you won't have the possibility, as Mr. Drake says, of any contamination.

THE COURT:   I understand that.   That's

not what I was talking about, though.    Would it be agreeable if I excuse all of them except these and let them stay there and you question all of them in

a group?

MR. DRAKE: Yes, sir, I think so.

Page 163

 

 

MR. COOK: Yeah, that's all right.

THE COURT:  I misunderstood you.   it thought you wanted to  line them up and close the courtroom and talk to  one at a time.

MR. DRAKE:  Well, I did ask that at one time, but I told you up in Huntsville I would meet you halfway.

THE COURT:  I'm trying to go the extra mile, but if that's agreeable, then, gentlemen,

I'll excuse the panel except for these 19. They

will remain and you may question then concerning their answer given to question 54, following which we will consider your challenge.

MR. DRAKE: Okay.

(Whereupon, at 3:55 p.m., with the jury venire present, the following occurred:)

THE COURT:  Ladies and gentlemen, we are going to recess until in the morning at 8:30. Now,

I need to keep a few of you here for some additional questions.  And I'll call out your name and ask that you stay for a few minutes longer with us for some more questions by the attorneys.   Those you that

are excused until in the morning -- and, of course, this applies to all of you -- between now and then,

Page 164

 

do not discuss the case with anyone, permit no one

to discuss it with you or in your presence. Do not discuss the case with members of your family, with friends, neighbors, or anyone else.  I would ask

you not to read anything in the paper about it or listen to anything on television.  I don't know

what might be printed or what might be on

television, but if you are listening to television or if you read the paper, you will be alerted to it by a by-line of some sort. So, please, remember

this admonition and just wait until later, at which

time you can go back and review it. But it is important at this time that you not discuss it with anyone or permit anyone to talk to you or to discuss the case with you.  Those of you, then, with the exception of those that I'll call out your name at this time, may be excused until in the morning at 8:30.

The following jurors please stay with us for a few additional questions.  Elizabeth Burns, James Collins, Phyllis Cook, Laura Costes, Nanette Davis, Eleanor Ewing, Margene Hinton, Betty

Holland, Mary Kizziah, Ervin Latham, Leigh

Locascio, Diana Mills, Elouise Montgomery, Guy

Page 165

 

Pate, William Porter, Watson Taylor, Doris

Townsend, Monica Woods, and Dorothy Yourick.

Now, with the exception of those people whose names I called out, the remainder of you may

be excused at this time until 8:30.

(Brief pause.)

THE COURT: Are you ready, Mr. Drake?

MR. DRAKE: Yes, sir, I am.

THE COURT: All right.

(Whereupon, Mr. Drake continued to' conduct voir dire examination of the jury venire as follows:)

MR. DRAKE: Ladies and gentlemen, we are concerned about the answer those of you who remain gave to this question No. 54, which I read out earlier.  The question basically is, "Do you think, based on what you have read or heard, that Betty Woods Wilson is probably guilty as charged?" All

of you who remain answered "Yes-"  Some of you wrote down comments, particularly in response to the

prior questions about what you had read and what

you understood the facts to be.  We are concerned that those of you who answered "Yes" there do in

fact think that Betty Woods Wilson is guilty as

Page 166

charged.  Are there any among you who do not believe that?  I mean, you have answered that you do.

A JUROR:  I'm Elizabeth Burns.   I thought possibly guilty, possibly she is, possibly she is not.  I don't know.  I guess I should have written

"I don It know, 11 but from what I have read in the papers there is a possibility.  You know, I can't

say for certain.

MR. DRAKE:  Right.  Yes.

A JUROR:  Aleen Costes, Laura Coste*s.  I think what my idea of when I read that, when I first read it in the paper, was my thought was, well, she probably did.  I mean, I'm being honest.  But I

don't mean that that is set in concretel and that if I were to hear the evidence and hear the true facts. I don't believe everything I read in the paper.  And I think that a lot of times what you see on the surface is not necessarily the truth, and that you may find out a whole lot more information and

change your mind.  I think all of us can change our mind. That's my opinion.

MR. DRAKE: Mr. Pate.

A JUROR: Really, I must have misunderstood the question, because today is the

Page 167

first I have heard of this case. I work 12, 14

hours a day, I-don't read the paper, I don't listen to the TV.

MR. DRAKE:   You still work for Harold Elliott on University Boulevard at all?

A JUROR: No, sir.

MR. DRAKE:   You did at one time, didn't you?

A JUROR:  Six or seven years ago.

MR. DRAKE:   Yes, that's where I

remembered you from.

A JUROR: I never did put that in view until you just said that, you know.   I have got a two-and-a-half-year-old daughter, when I come home

I spend time with her.  Undoubtedly I misunderstood the question.

MR. DRAKE:   Well, let's kind of go around and let everybody have an opportunity.

A JUROR:   That's what I was thinking.   I really misinterpreted the question myself, because it seems like it was asking more of what do you know of this trial, and I'm just really pretty much listening, you know, to what is going on around, hearsay and what is happening, and she supposedly

Page 168

 

did this, that, and the other.

MR. DRAKE:  Your name, again?

A JUROR: Monica Woods.

MR. DRAKE:  Okay.  Anybody else over here want to explain their answer? Mrs. Holland.

A JUROR: The way I read the question was if what we had read in the newspaper, did we believe she was guilty.   And the one or two articles that I read, they did indicate it, but I should be smart enough to know not to form an opinion based on

what's in the paper.

• JUROR:  That was my reaction, also.

• JUROR: Mine, too.

• JUROR: Yes, sir.

MR. DRAKE: Does that pretty much go for all of you?

A JUROR: That's the reason I put on mine that it was an unfair question.

MR. DRAKE: Let me ask --

A JUROR:  She has to be proven guilty.

A JUROR:  From the way the article was written, did I believe, and that's why I put --

A JUROR: What you read in the newspaper sound that way, I guess.

Page 169

MR. DRAKE: Okay. Let's kind of shuck it on down. Is there anybody here, now, among this group, who thinks that Betty Woods Wilson is

guilty? Any of you think that?

A JUROR:  We have got to hear from everybody. She is innocent until it's proven.   I mean, you have got to keep that in mind, you have

got to have an open mind to the situation. You

can't say, well, she is guilty and close your -mind. You don't need to be here.

MR. DRAKE: Would any of you assume going in that she was guilty?

A JUROR:  No, you can't do that.

MR. DRAKE: Do any of you believe for purposes of proof in this courtroom, that what you have read or seen or heard on TV is true?

A JUROR: Repeat that.

MR. DRAKE:  Do any of you assume that

what you have read in the newspaper or been told or seen on television about the facts of the case is true?

A JUROR: No, sir.

MR. DRAKE: All right, we are making some progress here. Let me ask about -- direct some

Page 170

specific questions to some particular people.   And

I have lost my chart, so I may not know where you

are at.  Well , you are sitting by that, you are

still sitting where you were.

A JUROR: Yes.

MR. DRAKE:  Diana Mills.

A JUROR: Right here.

MR. DRAKE:  Yeah . You had said in

response to question 53, 1 understand that Mrs. Wilson hired Mr. White to murder her husband

because he cut her out of his will.

A JUROR: This was in the paper.

MR. DRAKE: Okay.

A JUROR: That's why I said that, because

I was going by what I read in the paper, that is the way they indicated that.

MR. DRAKE: Okay. That was the exact words.  It would make a difference to you, I guess, if the true fact was he didn't cut her out of his will?

A JUROR: Well, I don't know that.   I haven't heard all the evidence yet.   I mean, I don't

know.

MR. DRAKE: Would any of you believe

Page 171

somebody under oath if we proved that he is a pathological psychopathic liar? Would you believe what he had to say?

A JUROR: You mean if you proved that he

is lying?

MR. DRAKE:  If we proved that he has lied his whole life about every matter of importance in

his entire life, that he is a compulsive

pathological liar, would you believe him?

A JUROR:  If you prove it?

A JUROR:  If you prove it, no.

MR. DRAKE: Okay. Let me see if I can

maybe end this thing right here. I sort of like

what Jimmy Fry did earlier when he asked if you all would promise him something. I'm going to ask you

on Betty's behalf will y’all promise me that you

are not going to put any weight on anything that you have read or heard or been told about this case?

Will you promise me that, every one of you?

Everyone raise your hand.  Okay.  All right.

Thank you very much.

THE COURT: Mr.  Fry.

MR. FRY:  State is satisfied, Your Honor. THE COURT: All right. Anything further,

Page 172

Mr. Drake?

MR. DRAKE: No, sir.

THE COURT: All right.  Ladies and gentlemen, those of you that remained for those additional questions, you may now at this time be excused until in the morning at 8:30.  The same instructions that I gave the entire panel apply to you, also. So do not discuss the case with anyone

or permit anyone to discuss it with you or in your presence.  Be back in the morning at 8:30.

(Whereupon, proceedings were in recess at 4:10.p.m., February 22, 1993, until the next following consecutive day, February 23, 1993, at 8:33 a.m., at which time, with the defendant and

all parties present, the following occurred out of the presence of the hearing of the jury venire:)

THE COURT: Let's see if everybody is

here. We have got the defense counsel and the prosecution and the defendant.

Before we start, is there anything

further from the State?

MR. FRY: No, Your Honor.

THE COURT: Anything further from the defendant?

Page 173

 

MR. DRAKE: No, sir.

THE COURT:  All right.   You gentlemen are ready to strike?

MR. DRAKE:  Yes, sir.

THE COURT:  Then there will be -- we have 95 jurors.

MRS. TURNER: Yes, sir.

THE COURT:  Gentlemen, there will be 81 strikes. The State, by virtue of striking first,

has 41 strikes.    The defendant has 40 strikes:  And, of course, the State  strikes first.   The last -- excuse me. And that   doesn't include the

alternates, does it?

MRS. TURNER:   No.  See, really, the 42nd strike is the State's second alternate and the 41st for the defense is their first alternate.

THE COURT:  Okay. Well, in any event,

the last two are alternates; right?

MRS. TURNER: Yes.

MR. DRAKE:  The way I understand it, if there is a -- replacements will be our strike and then the State's strike if there were two replacements.

MRS. TURNER: Yes. Right.

 

Page 174

THE COURT:  Beyond the 41st and the 40th strikes, that would leave 14, then there is an additional strike which would be the alternate; right, for each side? Which would be 42 for the State and 41 for the defendant.    I just want to make sure we are understood on it.

MRS. TURNER:   Before we get started, now, this young man, Mark Kell, No. 41, came in this morning and said he would have a problem being locked up, that he is a student.

MR. DRAKE: He is still on the list,

isn't he?

MRS. TURNER; Yes, he is still on the list. I thought I would relay that on.

THE COURT:   That information is being

made available to both sides, the information given to the clerk.

MRS. TURNER: This morning.

MR. DRAKE: Well, do you want to agree to let him go?

THE COURT:   It would be agreeable with

the Court, but --

MR. COOK:   That's agreeable with us.

THE COURT: All right.    I'll excuse

Page 175

 No. --

MRS. TURNER:  41.

THE COURT:  41. And that changes the -- MRS. TURNER:  composition is --

THE COURT:  -- to 41 and 41.

MRS. TURNER: Yes.

MR. DRAKE: Judge, it might be helpful for all of us if Doris will go through and let us know absolutely certain who is on.

MRS. TURNER: The ones that are off is

No. 29 --

MR. COOK: 29?

MRS. TURNER: 29, Cuple Gann. The next one is 37, that's the girl that got sick yesterday. 43, Hardin Kizziah.

THE COURT:  Hold on.  41 is also off?

MRS. TURNER: What's 41?

MR. DRAKE:  The one we just excused.

MRS. TURNER:  Yes. Let me mark him off here. Then 43 and 57.

THE COURT: Okay.

MRS. TURNER: Okay. That's five.

MR. COOK: What was the other one?

MR. DRAKE:  She said, "That's five."

Page 176

 

MR. COOK: Oh, I'm sorry.

THE COURT:  That leaves 94 jurors, and it means that your 41st strike is the alternate.        Each 41st strike is the alternate.

If you are ready, Mr. Fry, State's first strike.

MR. FRY:  No. 51.

MRS. TURNER: 51, S-1.    Debbie Little.

MR. DRAKE:  36 .

MRS. TURNER: 36, D-1. Bettye Holland. MR. FRY: No. 82.

MRS. TURNER: 82,   S-2.

MR. DRAKE: No. 3.

MRS. TURNER: No.   3, D-2.

MR. FRY: No. 75.

MRS. TURNER: 75,   S-3.

MR. DRAKE: No. 9.

MRS. TURNER:    No. 9, D-3.

MR. FRY: No. 39.

MRS. TURNER: 39,   S-4.

MR. DRAKE: No. 78.

MRS. TURNER: 78, D-4.

MR. FRY: No. 14.

MRS. TURNER:   14, S-5.

Page 177

MR. DRAKE: No. 16.

MRS. TURNER:   16, D-5.

MR. FRY: No. 68.

MRS. TURNER: 68, S-6.

MR. DRAKE: No. 99.

MRS. TURNER: 99, D-6.

MR. FRY: No. 48.

MRS. TURNER:   48, S-7.

MR. DRAKE: 62.

MRS. TURNER: 62, D-7.

MR. FRY: No. 87.

MRS. TURNER: 87, S-8.

MR. DRAKE: 35.

MRS. TURNER:   35 f D-8

MR. FRY: 22.

MRS. TURNER: 22, S-9.

MR. DRAKE: 34.

MRS. TURNER: 34.1 D-9.

MR. FRY: 54.

MRS. TURNER:   541 S-10.

MR. DRAKE: No. 80.

MRS. TURNER: 80, D-10.

MR. FRY: No. 84.

MRS. TURNER: 84, S-11.

Page 178

 

MR. DRAKE:  No. 79.

MRS. TURNER:  79, D-11.

MR. FRY: No. 8.

MRS. TURNER:  81, S-11.

MR. DRAKE: He struck No. 8 but it's his 12th strike?

MRS. TURNER:  12th, yes.   Excuse me. 12th.

MR. DRAKE: No. 12.

MRS. TURNER: No. 12, D-12.

MR. FRY: No. 15.

MRS. TURNER: 15, S-13.

MR. DRAKE: No. 7.

MRS. TURNER: No. 7, D-13.

MR. FRY: No. 77.

MRS. TURNER: 77, S-14.

MR. DRAKE: No. 10.

MRS. TURNER: 10, D-14.

MR. FRY: No. 91.

MRS. TURNER: 91, S-15.

MR. DRAKE: No. 11.

MRS. TURNER: No. 11, D-15.

MR. FRY: No. 74.

MRS. TURNER: 74, S-16.

Page 179

MR. DRAKE: 73.

MRS. TURNER: 73, D-16.

MR. FRY: No. 17.

MRS. TURNER: 17, S-17.

MR. DRAKE: 72 .

MRS. TURNER: 72, D-17.

MR. FRY: No. 47.

MRS. TURNER: 47, D-18 -- I mean, State 18, S-18.

MR. DRAKE: 53.

MRS. TURNER: 53, D-18.

MR. FRY: No. 71.

MRS. TURNER: 71, S-19.

MR. DRAKE: No. 88.

MRS. TURNER: 88, D-19.

MR. FRY: No. 60.

MRS. TURNER: 60, S-20.

MR. DRAKE: No. 86.

MRS. TURNER: 86, D-20.

MR. FRY: No. 5.

MRS. TURNER: No. 5, S-21.

MR. DRAKE: 98.

MRS. TURNER: 98, D-21.

MR. FRY: No. 46.

Page 180

 

 

MRS. TURNER:  46, S-22.

MR.. DRAKE: 59.

MRS. TURNER: 59, D-22.

MR. FRY: No. 25.

MRS. TURNER: 25, S-23.

MR. DRAKE: 28.

MRS. TURNER:  28 , D-23  18 apiece.

MR. FRY: 38.

MRS. TURNER: 38, S-24.

MR. DRAKE: No. 30.

MRS. TURNER: 30, D-24.

MR. FRY: No. 50.

MRS. TURNER: 50, S-25.

MR. DRAKE: 44.

MRS. TURNER:  44, D-25 .

MR. FRY: No. 58.

MRS. TURNER: 58, S-26.

MR. DRAKE: No. 67.

MRS. TURNER: 67, D-26.

MR. FRY: No. 55.

MRS. TURNER: 55, S-27.

MR. DRAKE: 49.

MRS. TURNER: 49, D-27.

MR. FRY: No. 61.

Page 181

 

MRS. TURNER:  61, S-28.

MR. DRAKE: No. 94.

MRS. TURNER: D-28.

MR. FRY: 83.

MRS. TURNER: 83, S-29.

MR. DRAKE: Judge, I think we need to consult a minute, and we don't have any place to do it, other than here.

THE COURT:  You need to consult with your attorneys?

MR. DRAKE:  Yes.

THE COURT:  okay. Do you want to go in the chambers?

MR. DRAKE:  That's fine.

THE COURT:  Why don't you go in chambers and we will wait on you, and we will make that available to you.

(Whereupon, proceedings were in recess for approximately 10 minutes, after which the following occurred:)

THE COURT: Okay. Now, the jury has been sitting out there for an hour, and it's going to be a little while longer.   I think we ought to give them a break.

Page 182

 

MRS. TURNER:  Yeah, them seats is mighty

hard.

THE COURT:  Do you want me to go out there and give them a break and instruct them, or is it

all right if Mrs. Turner goes out there and tells them to take about 20 minutes and come back?

MR. COOK:  I think Mrs. Turner -- if I

may, Judge, I think she can handle it.

(Brief pause.)

MRS. TURNER: All right, Jack, fire away. THE COURT:  Defendant's next strike.

MR. DRAKE:  21.

MRS. TURNER:  21, D-29.   12 more apiece. MR. FRY: No. 18.

MRS. TURNER:   18, S-30.

MR. DRAKE: 23.

MRS. TURNER: 23, D-30.

MR. FRY: No. 95.

MRS. TURNER: 95, S-31.

MR. DRAKE:  45 .

MRS. TURNER: 45, D-31.

MR. FRY: 92.

MRS. TURNER: 92, S-32.

MR. DRAKE: No. 56.

Page 183

MRS. TURNER:   56  D-32 .  Nine apiece. MR.FRY:   66 .

MRS. TURNER:   66  S-33 .

MR. DRAKE: 63.

MRS. TURNER: 63, D-33.

MR. FRY: 52.

MRS. TURNER: 52, S-34.

MR. DRAKE: 89.

MRS. TURNER: 89, D-34.

MR. FRY: No. 70.

MRS. TURNER: 704,   S-35.

MR. DRAKE:   I think we need to talk just a minute, again.

THE COURT: Well, it would be simpler

for --

MR. FRY: We can step out, Judge.

THE COURT:   -- for us to step out. (Whereupon, proceedings were in recess

for approximately 10 minutes, after which the following occurred:)

MRS. TURNER:   35 coming up.

MR. DRAKE: No. 4.

MRS. TURNER:   41 D.-35.  Six apiece.

MR. FRY: No. 24.

Page 184

MRS. TURNER:  24 , S-36.

MR. DRAKE:  No. 19.

MRS. TURNER:  19, D-36.  Five apiece. MR. FRY: No. 96.

MRS. TURNER: 96, S-37.

MR. DRAKE: No. 42.

MRS. TURNER:  42 , D-37  Four apiece. MR. FRY: No. 32.

MRS. TURNER: 32, S-38.

MR. DRAKE: 97.

MRS. TURNER:  97, D-38.   Three apiece. MR. FRY: No. 36.

MRS. TURNER: 26, S-39.

MR. DRAKE: No. 85.

MRS. TURNER: 85, D-39. Two more.

MR. FRY: 76.

MRS. TURNER: 76, S-40.

MR. DRAKE: No. 20.

MRS. TURNER: 20, D-40. Okay. This is the alternate.   Second alternate coming up.

MR. FRY: 27.

MRS. TURNER:   27, S-41.  That's the second alternate.

MR. DRAKE: No. 40.

Page 185

MRS. TURNER:   401 D-41.  That's the first alternate.

(Brief pause.)

MRS. TURNER:   Okay. Let's call them out. No. 1, Mark Allison.   No. 2, Roger Atteberry.   No.

6, Herbert Bruce.   No. 13, David Crawford.   No. 27, Thomas Ford.   He is the second alternate.   No. 31, Mavis Hall.  No. 33, Butler Hine.   No. 40, Daniel Junkin.  He is the first alternate.   No. 64, John Nero.  No. 6511 Davis Nichols.  No. 69, Guy Pate.

No. 81, Lois Smith.   No. 90, Morgan Tunstall.   No. 93, Milton Washington.    Is that 14?

(Brief pause.)

MRS. TURNER: All right.    I'll call them out, again.

MR. COOK: That's 14.

MRS. TURNER:   1 and 2.  6, 13, 27.  Put on there second alternate -- well, that's all right.

31, 33.  Then 40, 64, 65, 69.   81, 90.  90 and 93. (Brief pause.)

MR. DRAKE: Judge, we have a motion to make.

THE COURT: All right.

MR. DRAKE: Do you want us to do it in

Page 186

here?

THE COURT: We might as well.

MR. DRAKE:  I Im going to close the door. MRS. TURNER:  Close the door, Harry.

MR. DRAKE: We want to make a Batson motion.  We think that the jury was struck by the prosecutor utilizing impermissible race considerations.

I don't know how you want to handle the preliminary part of it, and, that is, the identification of blacks on the venire.    I can do that, and if Mr. Fry agrees with my identification, then maybe that would handle it.

The blacks who were struck by him were

No. 51, No. 82, No. 75.

THE COURT: Hold on.    You are not going in order and it's tough to keep up with you. No. --

MR. DRAKE: Do you want me to go in numerical order?

THE COURT: Well, if you have got it.

MR. DRAKE: Okay. No. 17, No. 48, No. 51, No. 55, No. 60, No. 66.

THE COURT:  Okay.   Keep going.

MR. DRAKE: No. 71 and No. 75 and No. 82.

Page 187

MR. FRY: Mrs. Turner, how many were there to begin with?

MRS. TURNER:  Let me look back here just a minute.

(Brief pause.)

MR. FRY: 94, is that one?

MRS. TURNER: Yeah, 94.

(Brief pause.)

MR. DRAKE:  Should I continue, Judge, just identifying people?

THE COURT: Yes.

MR. DRAKE: The other blacks on the jury would have been No. 561 Melvina McCoy.   No. 97, Monica Woods.  No. 93, Milton Washington.   No. 87, Bernice Stewart.   No. 81, Lois Smith.  No. 64, John

--Nero. Have I missed anybody?

(Brief pause.)

MR. DRAKE: So there were a total of 15 blacks on the venire.   The prosecution struck nine of those people, we struck two.

Might as well go ahead and say the reasons we struck.   We struck Melvina McCoy, No.

56, because her mother had been murdered.    And No. 97, Monica Woods, because she answered "Yes" To

Page 188

question No. 54 on the juror questionnaire.

THE COURT:  What number was that?

MR. DRAKE: 97.

(Brief pause.)

MR. DRAKE:  I suppose it's obvious, but race will be a factor in this case, in that it is likely that there will be evidence that the defendant had an affair with a black man who, I understand, will in fact testify. And, therefore, the jury will know that he is black.   So we th'ink that the exclusion of blacks for racial reasons is prejudicial to the defendant.

THE COURT: Anything else?

MR. DRAKE: Violates the rule announced first in Batson vs. Kentucky; it's denial both of equal protection and due process under the United States Constitution and the Alabama Constitution.

THE COURT: Anything else?

MR. DRAKE:  I have two recent cases in my notebook out there.

THE COURT:  I do not believe you have

made out a prima facie case of discrimination.

Mr. Fry, do you want to respond to his motion?

Page 189

 

MR. FRY:  I don't believe there has been

a prima facie case made, Your Honor.    Are there three or four blacks left after your last strike?

MR. DRAKE:  I will have to go back and look.

MR. FRY:  I think one of your last

strikes was a black person.

(Brief pause.)

MR. FRY:  Your Honor, without responding to the Batson, all I would say is there is -- 'a quarter of the jury is black.   It appears that this panel started out -- from which we struck -- with about ten percent black. And I would say that there's not been a prima facie case made by the defendant in alleging or proving that there has

been any systematic exclusion of blacks.     In fact, the black population is well represented on this jury.

THE COURT: The motion is overruled.     All right. Now, you gentlemen ready, and lady?

MR. FRY: Yes, sir.

MR. DRAKE: I think some of us might like to make a stop in the bathroom.

THE COURT: Well, what I plan to do,

Page 190

 

 

then, is to put the jury in the box and let them go

to the jury room, and we will take ten minutes and

be ready to start your opening in about ten

minutes .

MR. FRY: Yes, sir.

THE COURT: Hold on a minute. We have witnesses that are present. Mrs. Turner, do you swear witnesses?

MRS. TURNER: No, not usually.

THE COURT:  Do you have some witnesses that we need to swear in now?

MR. FRY: A couple.  And I have got a ton of them coming tomorrow.

THE COURT: I'm talking about a group of them that are here to be sworn in at this time.

MR. FRY: Only about two, Judge.

THE COURT: All right. And you have a question?

MR. FRY:  Yes, sir.  I don't know how you handle your opening. Will you allow me to reserve a rebuttal in opening?

THE COURT: Just one per side.

MR. FRY: Okay.

THE COURT: I mean, we have got to stop

Page 191

 

this thing somewhere.

MR. DRAKE: I'm for that, Judge. (Whereupon, at 10: 22 a.m., the following

occurred in the courtroom in the presence of the jury venire:)

THE COURT: Mrs. Turner, you going to

call their names?

MRS. TURNER: Yes.

THE COURT: Ladies and gentlemen, as Mrs. Turner calls your name, please come around and take your place in the jury box.

(Whereupon, the jury was duly impaneled.) THE COURT: Ladies and gentlemen, we are

going to take a ten-minute recess before we get started with the opening arguments in the case. During that ten minutes I'll let you go back to the jury room at the rear of the courtroom.  Please go into the jury room -- hold up and, if you will,

stand before you go to the jury room.  If you will stand and raise your right hand, Mrs. Turner will give you your oath for this case.

(Whereupon, the jury was duly sworn.)

THE COURT: Thank you, ladies and gentlemen.  You may go to the jury room.  We are

Page 192

 

going to take a ten-minute recess.

(Whereupon, proceedings were in recess at 10:25 a.m. , until 10:36 a.m. , at which time the following occurred:)

THE COURT:  Mr. Fry, do you have any witnesses in the courtroom that need to be sworn?

MR. FRY: No, I don't.

THE COURT:  Before we get started, before opening arguments?

MR. FRY: No, sir.

(Brief pause.)

MR. FRY: I'm going to ask for

Investigator Brantley to be excused, but this lady here is a family member, but she is not subpoenaed nor is she a witness . That's the victim's sister.

MR. DRAKE:  Some of these family members have been subpoenaed.  You may need to tell them if they are a witness that they need to leave the courtroom.

THE COURT:  I don't know who they are.   Do you mean from your side?

MR. DRAKE: I'm just saying some of them

expect you to make that announcement as a time when they get up and leave, is what I'm saying.

Page 193

 

THE COURT: You have some witnesses in

the courtroom that need to be sworn?

MR. DRAKE: No. I mean, I don't think we

want to do that right now.

MR. FRY: You don't want to --

MR. DRAKE: I didn't realize they had

talked about it. Nobody is going to invoke the rule

until after opening statement.

THE COURT: That will be fine. We will

swear them in and do it at that time.

Mr. Fry, are you ready?

MR. FRY: Yes, sir, Your Honor.

THE COURT: Mr. Johnson, if you will,

bring the jury out.

(Brief pause.)

THE COURT:  Mr. Fry, are you ready?

MR. FRY:  The State is ready, Your Honor.

THE COURT: All right. Mr. Drake, are

you gentlemen ready?

MR. DRAKE: Yes.

THE COURT: Mr. Fry, you may make your

opening statement.

(Whereupon, Mr. Fry addressed the jury in

opening statements on behalf of the State as

Page 194

follows:)

MR. FRY:  Good morning, ladies and

gentlemen.  Congratulations, I hope.  We will see,

I guess, as the week and the time passes by. We

congratulate you and, again, thank you for your

willingness to participate and serve on this jury.

As I told you earlier, I'm Jimmy Fry and

I'm the District Attorney for Limestone County,

Alabama, and I'll be prosecuting this case on

behalf of the people of the State of Alabama.  This

is a case that all of the people of the state have

an interest in, as in all criminal cases, not just

Madison County or Limestone County or even

Tuscaloosa.  So you all, as you sit here today, are

representing the people of the State of Alabama.

You are a composite of your neighborhood, of part

of Alabama that's basically, I guess, Tuscaloosa

County.  I want to thank you, of course, for your

service.

What you are going to do here in the next

days or the next week is important for everyone

involved.  You will become a part of the history of

the State of Alabama being on this jury.  And I hope

that something meaningful, something good, will

 

Page 195

come out of this experience for you.

Now, what are we doing now? This is the

part of the trial that is called the opening

statement. This is where we get to give you our

explanation, the lawyers, that is, of what we think

the trial is going to be about. Yesterday you all

sat out there and answered questions for us and you

responded that basically you didn't know anything

about this case, maybe you had read something in

the newspaper, maybe you had heard something on the

radio, but personally you didn't know anything, or

at least not much. So we are kind of starting out

here kind of like this whiteboard -- used to be a

blackboard, now they are whiteboards -- clean

slate. You all don't know what is coming to pass.

You are like that board, waiting -- your mind' is

like the board, waiting to be written on, to have

the blanks filled in. There is a beautiful Latin

word, tabula rasa, which, I believe, means clean

slate. And that's where you all are right now.

Your mind is like a clean slate -- at least that's

what we hope, that's what we think. But it would be

a little bit unfair to you all to have to begin

hearing witnesses and taking testimony right away,

 

Page 196

without knowing anything about the case. So here

and now we get a chance to give you all what you

might call a jump start or a head start into the

case, to tell you what we think is coming up.

When I was a kid seven and eight and nine

years old, I had one of the best babysitters in the

world. My babysitter was a movie theater. My mama

worked at the telephone company, and right next

door to the Ritz Theater was the Bell Telephone

Company where she worked as a clerk. And I would

get out of the elementary school in the second and

third grade, walk the two blocks to her office, and

every afternoon from 3 o'clock until mama got off

at 5:00, I sat in the Ritz Theater. 15 cents to see

a movie, and a dime would get you a bag of popcorn

and a little Coke. one thing I-'Il never forget --

and every time I talk to a jury I think about

this -- is that big screen and the way I remember it

in black and white, "Previews of coming

attractions." And they told you what was going to

be on the next week. Sometimes the previews were

about as good as the movies. What you are getting

right now is your previews of coming attractions.

Why are we here today? Why are you here

 

Page 197

today? What is it that you all have to determine in

this case? What is your job going to be? Well, you

are going to have to determine whether this woman

over here did something or didn't do something.

And you really don't know what exactly, you have

had it kind of danced around a little bit the last

day or two, about what I and the State of Alabama

are alleging that she did, but I think you need to

know.  I think you need a little road map as we go

through this case of things you need to be thinking

about or considering, so that you will be able to

make a decision at the end of the case.

So where are we? Well, this whole thing

started out -- at least as far as the court system

goes -- with an indictment, a piece of paper, a

formal piece of paper, a document, being returned

by the grand jury up in Huntsville, that is,

Madison County, Alabama, back in June of last year,

that is, 1992.  And they heard evidence, not a

trial, just one side was represented.   It was a

grand jury, it wasn't a jury like you all. They

heard evidence and based on what they heard they

returned this indictment, sending this case, then,

to be heard by a Judge and a pettit jury to

 

Page 198

determine the actual guilt or innocence of this

defendant.

Now, they didn't find anybody guilty in

Madison County by returning this indictment.   All

it does is establish what is called probable cause.

That is to say that this case needs to be heard by a

jury .They were people just like you, they weren't

judges or lawyers, and they returned this

indictment.  And let me read it to you so you will

know what the charges are.

"State of Alabama, Madison County. The

grand jury of said county charge, that before the

finding of this indictment, Betty Woods Wilson,

whose name is unknown to the grand jury other than

as stated, did intentionally cause the death of Dr.

Jack W. Wilson, pursuant to a contract, to-wit:

Betty Woods Wilson agreed to pay James Dennison

White money, to-wit:  $5,000 in United States

currency, to kill Dr. Jack W. Wilson, and James

Dennison White did kill Dr. Jack W. Wilson, by

beating him with a baseball bat or other blunt

instrument, or stabbing him with a knife or other

sharp instrument." And that was against the peace

and dignity of the State of Alabama.

 

Page 199

There is a second count that kind of says

the same thing, I guess, in a different way.  The

Judge will explain to you how you can receive these

counts at the end of the case.  She can't be

convicted but one time.  You can consider these

counts.

Count Two says, "The grand jury of said

county charge, that before the finding of this

indictment, Betty Woods Wilson, whose name is

unknown to the grand jury other than as stated, did

intentionally cause the death of Dr. Jack W.

Wilson, for hire, to-wit: Betty Woods Wilson hired

James Dennison White to kill Dr. Jack W. Wilson, by

paying James Dennison White, to-wit:   $2 , 500 in

United States currency, and promising to pay James

Dennison White more money, to-wit: An additional

$2,500 in United States currency, and James

Dennison White did kill Dr. Jack W. Wilson, by

beating him with a baseball bat or other blunt

instrument, or stabbing him with a knife or other

sharp instrument, in violation of the Code of

Alabama." And, again, against the peace and

dignity of the State of Alabama.

Those are the charges.  This is going to

 

Page 200

be the bottom, line for you all in considering at the

conclusion of this trial whether or not this woman

paid a man to kill her husband and did he in fact

kill her husband pursuant to that contract.     Did

James White kill Dr. Jack Wilson, and did he do it

pursuant to a contract for money or promise of

money given by this woman.

Now, what are the facts of our case going

to be? By the way, our case is going to come to you

all from right here, the witness stand, by

witnesses called to testify about things that they

have knowledge of from maybe photographs, exhibits,

documents, things that you can touch and feel, some

of which you probably will take back to the jury

room with you and look at.   Speaking testimony and

physical evidence that you will be able to have,

all will play a part in this case.

What are the facts going to be?   Well,

the facts are going to be, to begin with, that a man

is dead.  Dr. Jack W. Wilson.    He was a good man and

a decent man.  And he has been murdered,

dreadfully, painfully murdered.     The last day of

his life, the evidence will be, he was with this

woman, his wife, in Huntsville, Alabama, on the

 

Page 201

22nd of May of last year.   And they were,

apparently, preparing to go on a trip the next

morning, which would have been a Saturday morning,

to Santa Fe on a vacation.   He was with her at lunch

after having worked in his office that Friday

morning, seeing patients.    Dr. Wilson was an eye

doctor, or ophthalmologist.    He was a doctor.   He

waited on patients that morning.    He had lunch that

day with his wife and some people that were up there

at the house.   Went back to work that afternoon,

left work probably about 4:30, got back to his

home.  The testimony and the evidence is going to be

that sometime around 4:30, a man by the name of

James Dennison White, whom I expect you will get to

meet very shortly, was waiting on him there in his

home.  And that he was waiting there for the express

purpose of killing Dr. Wilson.    He had been there

for some time, the evidence will be.    He was

nervous, he was anxious.    And when Dr. Wilson came

in, he set upon him and that night when Dr. Wilson's

body was found some approximately five hours later,

his forearms were beaten and broken, his skull was

beaten and crushed from an aluminum bat.     He had

been stabbed in the abdomen, one of the major veins

 

Page 202

or arteries in his abdomen had been pierced. He

died in his home, second story of that house, just

outside his wife's bedroom, in a pool of his own

blood. Well, that's Dr. Wilson.

What is our evidence about this woman,

the defendant? our evidence will be, ladies and

gentlemen, that she was a vain, selfish woman. She

was obsessed with her own image and her own

appearance, with having things, with having a house

and having a car, having two cars. The evidence

will be a Mercedes convertible and a BMW. Having

everything that all of us, I guess, would think of

as the good life. And our evidence will be, ladies

and gentlemen, in this case, that although it would

appear that she had everything, she wanted more.

in fact, she didn't want more, she wanted it all.

She wanted it now.

We are going to prove to you, ladies and

gentlemen, that Dr. Jack Wilson was a loving and

devoted husband, that he showered his wife with a

good life, with a magnificent home in a fashionable

neighborhood, designer clothes, jewels, furs,

whatever she wanted to make her happy, but his

treatment wasn't the same.  The testimony will be

 

Page 203

that this defendant in public places made

derogatory remarks, rebuked her husband publicly,  

called him names, cursed him, humiliated him in

front of clients and workers at his place of

business.  And that in fact she told some of her

closest friends that she was disgusted by Jack

Wilson, and the only reason she didn't leave him

was because she might lose her lifestyle.  She

couldn't give that up.

Mrs. Wilson, you are going to find out,

had a public life and she had a private life.  She

had a life people knew about, she had a life that

only a few people knew about.  You are going to find

out that there was a secret Betty Wilson, a secret

Betty Wilson who took money from her husband

without him knowing it, that had lovers into the

house he gave her, had lovers in Birmingham and in

New York and wherever she wanted to go, that were

secret.

Why did this all come about, then?

That's a little bit about Dr. Wilson and a little

bit about Betty.  How did it all come about? Well

we have got to add another figure to this story.

You see, this story, what you are about to see this

 

Page 204

week, I think it's like a triangle, three sides.  I n

the center there is a fellow by the name of James

Dennison White. And on one side of the triangle is

this woman, Betty Wilson. On the other is her

sister and not only her sister, her twin sister,

Peggy Lowe. I guess at the bottom, actually, of the

triangle, then, is Mr. James White, because you   are

going to see that these two women, working with Mr.

White, dealing secretly with Mr. White, brought all

of the elements together that made this tragedy

happen. Just like putting wet hay in a barn and the

hay begins to mold, and sometimes you have

spontaneous combustion, all of the elements are

present when hay is wet and it' s in the barn and it

catches on fire, you take all of the elements apart

and nothing happens, but you put all right elements

together under the right circumstances, and you get

spontaneous combustion, you get fire. Well, in

this case the elements were this woman, James White

and her sister, Peggy Lowe. And the three of them

coming together at a place and in a time and under

circumstances, have created this tragedy.

Well, I mentioned Mrs. Wilson, you all

heard old James White mentioned yesterday in voir

 

Page 205

 

dire, and you are going to hear, I'm sure, a whole

lot more about him.  How about James White? What's

the story on James White? Well, I think the story

is going to be that he grew up around Sylacauga.    I

don't think his parents were married, I think he

took his daddy's name the first 15, 16, maybe 20

years of his life.  Later on maybe took his mother's

name.  I don't think his parents were married.   He

wasn't born with a silver spoon in his mouth, in

other words.  Had it kind of rough growing up.' A

lot of us do, a lot of people do.  Joined the Army

when he as 17.  Now, folks, I believe, if I'm not

mistaken, that was in about 1967 or 1968.   Some of

you all may remember, as I do, that the Army was the

happening place to be in '67 and '68, or maybe it

wasn't the happening place to be, depending on how

you felt about the war.  But as a young kid, he

signed up, joined the Army.   He wasn't drafted,

joined the Army to go off to war, and he did, he

went to Vietnam. While he was there, like a lot of

other people, he got screwed up. He was sent home. Messed up. An alcoholic. A pill-popper. Using drugs, marijuana.  And from the time he got out until, I guess, within the last year or two, he has

Page 206

 

been in and out of VA hospitals, he has been here in

Tuscaloosa, he has been in Birmingham. Not going

to get any awards for good citizenship.

But what happened to him? Well, in the

summer of '92, James had been married to a woman for

several years, and they had two children together,

and unexpectedly she moved out and left him.  In

fact, I believe moved in with his best friend.  I

say she moved out, I don't believe that's right.  I

think she kicked him out and his best friend moved

in.  Mr. White was pretty upset about that. He was

depressed and disconsolate.

In August of last year, then -- excuse

me -- not last year, '91. In August of 191 he began

working as a maintenance person at Vincent

Elementary School, which, I believe, is in Shelby

County on Highway 231 going towards Pell City.  He

wasn't a full-time employee, he was not a state

employee, or I think -- or not on the payroll of the

Board of Education, but he was building shelves

kind of on a contract basis or part-time basis.  And

there was a lady there teaching by the name of Peggy

Lowe, who is the sister to this defendant.  And they

are twins.  I don't think they look exactly alike,

Page 207

but they are twins. And somehow or another this old

fellow from Sylacauga, just divorced, and this nice

schoolteacher, Ms. Lowe, struck up a friendship.

Mrs. Lowe is married, by the way, has a couple of

kids.  And her husband also is a schoolteacher in

 

that same school system. But they began talking to

each other and James was awfully struck by Mrs.

Lowe. Here he saw, for the first time, I think, in

his words, "A woman of another statute," his words.

Another class. That was taking up time with him,

being nice to him.

And I think the evidence will be he

became, to say the least, infatuated with her and

they developed what you might call a telephone

romance, calling each other, talking sometimes

hours at a time. This went on beginning sometime

around the first of the year of '92, up until the

spring.

Now, their romance, as far as I know, was

mostly over the telephone.  And he was telling her

he had strong feelings for her, she told him that

she had strong feelings for him. This had old James

pretty worked up. So that by March or April of

1992, I guess you could say he would do almost

Page 208

anything for Mrs. Lowe, because she began talking

about how unhappy she was with her husband and how

she wished he wasn't around.  Not Dr. Wilson, now,

another man, her husband.

James is going to tell you he said,

"Well, you know, something could probably be

arranged," but nothing was.  The talk went on and

on, and then there came a time in the spring last

year when Mrs. Lowe told James, you know, "My

sister is awfully unhappy." First she didn't tell

him who it was, but eventually she said, "My sister

is awfully unhappy, she's just miserable, she would

like to have something done about her situation.

She's married to a man she is disgusted with."

Again, James said, "Well, maybe something could be

done, something could be arranged. Maybe I could

talk to somebody for you." Next thing you know they

ask him -- Peggy asked him, told him, "Well , how

much would this cost?"  He said, "I don't know.

$5,000. $5,000. Give me $5,000 and we will have it

done."

Guess what? The facts are going to be

that James White -- he was broke in April of 1992,

suddenly came into some money about the first part

 

Page 209

of May 1992.  He is going to tell you he was paid

$2500, half the money up front, to do the job, kill

Dr. Jack Wilson.  And he took the money and paid

bills, thinking maybe that's the end of it, but it

wasn't.   Because he is going to tell you that the

defendant, Betty Wilson, and Peggy Lowe, then began

working on him to get something done.   He had his

money.  What-s the deal? What's going on here?

Let's see something happen.   He is going to tell you

that on May 15th last year, that is, 1992, that he

rode by over to Huntsville and actually went to

Huntsville and, as they say, cased the job.    He

wanted to see where Dr. Wilson's office was, where

his house was, but also he needed some more money.

He had spent the $2500.   And he told these ladies he

needed $200 expense money.   You know, any good hit

man needs expense money.   You can't be riding all

around the State of Alabama, casing places, without

some expense money.

Now, the evidence is going to be that the

next night, on the 16th of May, 1992, James White

went to the state park in Guntersville, Alabama, in

Marshall County, and he was supposed to have picked

up a book with money in it, $200.   He was supposed,

 

Page 210

he is going to tell you,     [covered by post-it

lodge, reached into the       post-it note

black BMW, which would b      that was

parking area there at the      copied          ay,

is probably a mile                with        come

in -- he was supposed to reach     page]      d be

opened, the book would be there, take the book and

it would have money in it or get   the money out of

the book.  Well, he got there too late.     I don't

know if you all know this, but they close some of

the state parks at night.    Even when they have got

guests there, unless you are a guest or have some

special authority to enter after 9, 10 o'clock at

night, they won't let you in.    So James was stuck.

He couldn't get in to get his money.    They told him

to go down the road, you can call the front desk and

maybe somebody can bring   this book to you.

Well, the evidence is going to be, ladies

and gentlemen, that Mrs. Wilson went with a

security guard to her car, got the book out of the

car, gave it to the guard, told him to take it to

James White, tell him to have a good time, she

wanted the book back.    The guy drove the mile or

whatever to the front gate, gave him the book, he

 

Page 211

left and went back to Vincent, Alabama.

Now, the next week, the testimony is

going to be, he still hadn't committed the murder,

and he told these ladies, "Well, I don't have a gun.

I have been looking for a gun but I don't have a

gun.  I don't have a gun. I have an old gun but I

can't get bullets to fit it."  So the evidence is

going to be that on Wednesday, May 20th, these

ladies brought a gun to James White and gave it to

him on the dam at Logan Martin Dam, which is a dam

that I think connects probably Talladega and Shelby

County there, just on the other side of Vincent.   A

little, I call it almost an earthen dam, it's not

like dams I'm used to up in North Alabama, like Joe

Wheeler and Wilson, but a small dam.  He is going to

tell you there an exchange was made and he got a

pistol from these ladies.

On Thursday, the 21st of May, he drove to

Huntsville, Alabama, and was outside Dr. Wilson's

office at 6 o'clock in the morning, and he decided

he couldn't do it. I think he will tell you he

probably just decided he would get caught if he did

it.  In Huntsville, in that area where Dr. Wilson's

office is , near a hospital , was busy even at 6

 

Page 212

O'clock in the morning.  And be made a phone call to

Mrs. Lowe and talked to Mrs. Lowe and to the

defendant, who on this day, as the day before, was

over in Talladega visiting with her sister.

Remember the day before they exchanged the gun, she

was still over there.  We are going to prove to you

he told her, "I need some more money."  She said,

"I'll meet you in Huntsville."  Told him where to

meet her.  And at around noon that day she is back

in Huntsville, she is back in a mall, a shopping

center there called The Heart -- excuse me --

Parkway City Mall. we are going to prove to you

that night there were calls made by James White

from a motel in Huntsville, Alabama, to Peggy Lowe.

We are going to prove to you the next day James

White was taken by this defendant from the Parkway

city Mall at around 2:30 and taken to Dr. Wilson's

house, where he was to lay in wait there until Dr.

Wilson came in and attacked him.  Well, the plan

went off, he was taken there.  Something happened,

Dr. Wilson was late, he should be there in maybe 30

minutes, but be wasn't.  Time passed by.  3 o'clock,

3:30, 4 o'clock. And finally, James White is going

to tell you that after a couple of hours of waiting

 

Page 213

Dr. Wilson came home, that they were face to face,

that he broke into an affray. James White is going

to tell you that he accepts the responsibility for

Dr. Wilson's death and that he went there for the

express purpose of killing him.

Now, the plan was that James White was

going to walk away from 2700 Boulder Circle, which

is kind of over on a hillside, or maybe you might

say Mountainside, in Huntsville, by walking through

the neighbor's back yard, skirting the back yards

to get back to the main thoroughfare. Well, he

panicked, he got scared, he decided, you know,

that's not a good idea. If somebody sees me in

their back yard in this neighborhood of doctors and

lawyers and engineers, they may call the police.

So he stayed in the house, and at about 5 o'clock

that afternoon this defendant came back to the

house, probably unplanned as far as meeting James

again, and James is still there. He is supposed to

be gone. So he gets in the car with her, crawls

under some clothes in the back seat of her BMW that

she had bought that afternoon, on hangers, plastic-

covered clothes, for the trip, I suppose, the next

day. And he was whisked away.

 

Page 214

Well , James gets taken to within a mile

or so of where his truck is parked.  He walks to his

truck, gets in his truck and drives back to

Vincent, Alabama, where he lives, stopping on the

way to call his brother and let his brother know he

is coming home, he will be late.  Buying beer,

bought some beer.  And a couple of days later the

police, following a lead, are in Shelby County and

talking to James.  And James breaks down after some

questioning, and begins to tell little bits and

pieces of his story.  And he is not very honest in

the beginning. I guess he doesn't know whether he

is caught or not.  By bits and pieces, he begins to

tell the story.  He is taken to jail in Huntsville,

and then about a week later this defendant is

arrested.

          Now, James White, I expect, is going to

testify in this case and talk to you all . You may

like him, probably not.  You may feel sorry for him,

maybe not.  But he is going to testify. We are

going to present evidence that we think you will

believe corroborates or, that is, suggests that, at

least in part, about some important things that

James White is telling the truth.

 

Page 215

James White was given a deal, a "deal."

Before I got into the case, I guess last summer

sometime, when there was another District Attorney

over in Madison County, who since has gone out of

office, he was given a deal, and I'm sure that will

be a part of the case. We will ask James to explain

to us his understanding of that to you all . But I

believe the evidence will be that he was allowed or

will be allowed to plead guilty to murder, not

capital murder, but murder, be sentenced to life in

prison, not life without the possibility of parole,

but life, in exchange for testimony, providing

evidence in this case, all of which has to be

corroborated by independent evidence.   In other

words, his deal was not just to make up a story, but

to tell Investigator Brantley and the people with

the DA's office in Huntsville, before I ever got

involved, facts that could be proven outside of

James White's statement.  And if he doesn't do

that, if he fails to offer evidence that can be

corroborated, then he doesn't have a deal, then he

will be prosecuted for capital murder.

I didn't make the deal.  I'm stuck with

it.  Do I like it? I don't know, doesn't really

 

Page 216

matter whether I like it or not. The deal is, as I

understand it, Mr. White has to tell the truth.  If

I can prove that he lies about something, Mr. White

is in a lot of trouble, more than he is now.

You all are going to have a lot of

witnesses in the next couple of days, many, many

witnesses.  Some of them, a few of them, probably

will be long witnesses, others will be short and

brief, maybe just a few questions.

This case, in my case that I'm going to

present to you all, is not going to be given to you

as a portrait all nicely painted and finished and

paneled and framed and ready to be given to you.

It's not one of those I can do like that.  This case

is going to be given to you a piece at a time , piece

at a time, a little bit at a time, because I want to

convince you in this case, and I want the evidence

to prove to you in this case, the guilt of this

woman, not just on what James white says but on

evidence outside of that, and based upon what we

know about this woman herself.  For instance, that

she stands to gain, it will be proven in this case,

that Dr. Jack Wilson's estate, she was the primary

beneficiary, if you will, the primary heir in his

 

Page 217

estate.  A gentleman is going to come from a bank to

tell you what his estate was valued at, but I

believe the evidence is going to be that her share

would have been something like $4,000,000 with him

dead.  You see? All of it, not part of it.  So we

are going to try -- I'm going to try, as best I can,

to put these witnesses on and keep this thing

moving in an orderly fashion for you all, and

hopefully make sense to you.

If I do anything during the trial that

offends anyone or annoys anyone, I'm sorry, I'm

doing the best I can.  I'm in a strange courtroom

and living out of a motel , just like you all are

doing, and doing the best I can being down here with

what I got.  But I look forward to getting this

evidence before you and I look forward to not

telling the story but showing you the story from

the witness stand and by exhibits that are going to

come in.  And I see from the serious expression on

your faces that you know this is serious business.

And I thank you in advance for your attention and

the consideration which I know you are going to

give this case. Thank you.

THE COURT: voir dire by the defendant --

 

Page 218

I mean, opening statement.

(Whereupon, Mr. Cook addressed the jury

in opening statements on behalf of the defendant as

follows:)

MR. COOK: May it please Your Honor,

Judge Younger, Mr. Fry, members of the prosecution,

ladies and gentlemen of the jury.

I'm glad to see at least. one or two about

my age. I'm not going to tell you anything about my

childhood, and I'm not going to give you any '

stories about movies, and I'm not going to give you

any Latin expressions. My opening statement is

going to be probably shorter than Mr. Fry's.  I

don't feel that it is necessary for me to inform

this jury of its responsibility, because I feel

like that you already know what your duties and

your responsibilities are.

This case and every case in the hall of

justice -- and this is a hall of justice --

ultimately will not be decided upon what either I

or Jack Drake or Mr. Hooper or Mr. Sandlin says, it

will be decided upon what this jury finds the truth

to be from the witnesses who are sworn and testify

in this case.  I want to tell you just a little bit

 

Page 219

 

about our side of the case. Mrs. Wilson has entered

a plea of not guilty in this case. And let me say

to this jury at the outset, that it is her

contention and our contention that she is in fact

not guilty. We expect the evidence in this case to

show that she did not enter into an agreement, a

conspiracy or a complicity or whatever you wish  to

call it, to kill her husband, Jack Wilson.  She

pleads not guilty and we say to you that she is not

guilty, not by virtue of some technicality, not  by

virtue of some legal loophole, but by virtue of  the

fact that it is the truth.

Betty Wilson, as she sits here at the

council table, will not at any time, nor will Mr.

Drake or any of us , indicate or have this jury to

believe that she is sainted; she has her faults.

Don't we all.  Se. has admitted voluntarily that she

has had affairs, and for that she is to be

congratulated, but that is not what she is charged

with in this case.

The evidence will show that their

marriage was not a marriage such as I have or such

as many of you have.  It was not, indeed, what I

would describe as a conventional one.   The evidence

Page 220

 

 

will show that Betty and  Jack Wilson married in, I

believe, July of 1978, that each of then prior to

that marriage had three children of their own by a

prior marriage.  Betty has three children, Trey,

Bo, and Dink.  Fine young sons who are grown, 27,

25, 23.  And she has two grandchildren.  Dr. Wilson,

on the other hand, had an adopted son, Kenneth

Perry.  Two sons of his own, Scott and Steve.

The evidence will show in this case that

Betty Wilson was an alcoholic for a number of

years.  The evidence will show that she has been

cold sober for the last six years and has

religiously attended and participated in Alcoholics

Anonymous meetings and other drug programs, almost

on a daily and a nightly basis.

My friend Mr. Fry tells you about Betty's

twin sister, and they are twin sisters.  Peggy Lowe

lives in Vincent, Alabama.  She is married to Wayne

Lowe.  She is a schoolteacher, she teaches the

first grade, still teaching the first grade.   She

is married to her husband, Wayne Lowe, who is a

music director of the Baptist Church, the First

Baptist Church, and who also is a schoolteacher and

who also drives a school bus.  The evidence will

 

Page 221

 

show that their marriage is a very good one, it has

always been a good one, and that there has never

been any loveable or intimate relationship between

James White and Peggy Lowe.

And I might say that Mr. Fry tells you

that Mr. White was not born with a silver spoon wit@

his mouth, neither were the twins.  They were

raised in Gadsden, Alabama, where their father was

a policeman and their -mother was a textile worker.

A lot of us were not born with a silver spoon in our

mouth.

The evidence would show in this case that

Mrs. Lowe and Betty Wilson, although different

lifestyles, that they both liked to help people,

particularly people who are homeless, people who

cannot help themselves, people who are down on

their luck, people who have a drinking problem or a

drug problems  And the evidence will be clear that

both of them have done that for many years.

The evidence will be in this case, that

James White was not an employee of the school, but

has done some odd jobs for several of the

schoolteachers in the Vincent Elementary School.

He had built some shelves and he built some

 

Page 222

 

shelves, also, in the classroom of Peggy Lowe.

The evidence will show that he did some

carpentry work for Wayne Lowe and Peggy Lowe at

their house, and was paid for it.   The evidence will

show, if you will, please, that he poured a

driveway for Wayne Lowe's mother and was paid for

it.

The evidence will show that in August,

when the State contends this relationship between

Peggy Lowe and James White commenced, the evidence

will show that at that very time that Wayne Lowe --

not Wayne Lowe, but that James White went to the VA

Hospital for one or two days with the complaint

that he was having visual hallucinations and

auditory ideations, that he was constantly hearing

voices and he didn't know what they were saying.

And then he left without proper medical treatment.

The evidence in this case, the State's

case, in accordance with the plea agreement --

which I'm glad to hear Mr. Fry say -- I thought I

heard him say that he didn't know whether he

approved of it or not, because it is a strange

animal.  And I'll tell you that and you will see it

and hear about it later on in this case.    And it's

 

Page 223

 

somewhat shocking, isn't it, Mr. Fry?    But the

State's case is predicated upon the believability

of James D. White.

And let me tell you a little bit -- just a

little bit, because I don't have time to give it all

to you, about the history of James D. White.    And I

don't want to hear -- Mr. Fry has told you about

this story about, oh, he went to Vietnam and got

screwed up.   He was screwed up before he ever went

to Vietnam.   I came from the generation that went to

World War II.  In fact, I came back here to this

city and enrolled in a great university, five

months after the Japanese surrendered and two

months after I had landed in San Francisco.    James

White was discharged from the Army of the United

States on account of character and behavior

disorders.   His behavior was not due to an

incapacity to become a satisfactory soldier, it was

due to the fact that he shirked his duties and

deserted his post.   And if everyone in my war had

deserted their post and shirked their duties, we

would have been speaking either Japanese or German.

He was convicted for selling drugs.    And

before being sentenced by a Judge., such as Judge

 

Page 224

 

Younger, fled from the jurisdiction and became a

fugitive, and had to be picked up in another state

and extradited back to this jurisdiction.

The evidence will show in this case --

and you don't take it from me. As I said earlier,

you take it from what the witnesses say in the

witness box -- that he is now, that he was last

year, and he has been for the last 25 years, a

pathological liar, from whom no businessman or no

person on this jury, I suggest, would rely upon his

word in their most private affairs or in making

business judgments or, stated another way, he is

not someone that you would want to buy a used car

from.

It is most interesting that the evidence

will show, and we will prove to you beyond any

peradventure of a doubt, that he not only lies

about things that are to his advantage and to his

benefit, but he lies even about unimportant things.

The evidence will show that for the past

20 years or more, that he has been diagnosed

repeatedly as being psychotic, paranoid with

suicidal tendencies, which he has attempted from 12

to 14 times, that he has been continuously addicted

 

Page 225

to alcohol, to amphetamines, to organic -solvents,

to marijuana, to opiates taken intravenously, and

to LSD.  And that the only period of time in the

last 20 years in which he has been free from drugs

and substances is when he was in the penitentiary.

The evidence will show that he has

engaged in sexually abusive behavior with his own

daughter while drunk.  The evidence will show that

he has been angry with and has, in fact, hated

females since his high school days.

The evidence will show, according to his

very medical records and his own admission, that he

wrote a letter to his stepfather's wife asking her

to have sex with him.  And the evidence will show

that he stabbed a Marine with a fork, or so he says

in his history.  Some of the Marines that I knew, I

do not believe that he would have stabbed them.

He has a history of blackouts, associated

with drinking and violent behavior. His medical

records will show that he has blamed all his

troubles on the Government, that he admits to

excessive violence and unexplainable violence while

drunk or on drugs.  That for over 20 years he has

been angered and bitter at the world, blaming his

 

Page 226

 

troubles on others.

And he says that he was mysteriously

given an undesirable discharge, although in the

same breath he says in these medical records that

he pulled an M-16 on military personnel. H i s

medical records show that he is likely to fantasize

and daydream extensively, that he is rebellious,

resentful, non-conforming, he conflicts with

society and authority figures, and projects blame

and hostility. And, very importantly, that he may

chronically misinterpret the words and actions of

others.

This is only a little bit about the

State's star witness. I can tell you what I know

about him. I have never seen him except on

television, where his own lawyer refers to him as

being "con-wise," whatever that may mean.  We do

know that -- we do know that he has given seven

different statements that are recorded and which

were required to be given to counsel in this case

under the rules of this court. We also know and

believe, and the evidence would show, that he has

made many, many other statements that have not been

recorded or written up, but the statements that we

Page 227

 

know about and that the evidence will disclose, is

a statement that he gave on May 26th, one on May

27th, one on May 29th, one on 4 June, one on 24

June , and the other on 28 July , all in 1992.

I can say to this jury with absolute

candor, that the proof in this case, coming from

the mouth of James White, will show that in each of

these statements that he has repeatedly and

repeatedly and repeatedly lied and contradicted

himself . Seven known stories or versions.  All

different, all conflicting.  Many of which make

absolutely no sense at all.  And I predict to this

jury, as you sit in this box, that you will even

hear different stories today and tomorrow or

whenever he takes the stand, than you have in these

seven different versions.

And let me speak to two of those now. And

I ask you and I know this jury will be attentive and

will remember the evidence, what I have said and

what Mr. Fry has said. Mr. Fry said -- and I only

heard this for the first time, because this is, not

in any of his statements - - that it was on

Wednesday, May the 20th -- May the 20th, Wednesday,

that he went to Logan Martin Dam and got a gun or a

 

Page 228

 

pistol or revolver from Peggy Lowe and Betty

Wilson. In the first place, he has not gotten a gun

or a pistol from Peggy Lowe or Betty Wilson, he

stole the gun out of the house. But in all of the

statements he has given, in every single one of

them -- and the evidence will show that -- he first

started off saying he definitely knew that he got

the pistol on May 12th, on Tuesday, May 12th.  And,

again, then they found out that that was a bad date,

and ten days later they moved it to May the 19'th.

And it's been another Tuesday, and it's been May

the 19th, up until the present time, and I heard

today for the first time that it's Wednesday, May

the 20th. But when he takes the stand it might be

the 18th or the 21st, we will wait and see, but this

is from what Mr. Fry said the evidence would be.

He also -- Mr. Fry also said a moment ago

that on May the 15th he came to Huntsville and cased

the house or cased the place where Dr. Wilson

worked, and then he went back to the state park in

Guntersville. That might be what he is going to

say, but that's not what he said thus far. It is

different and contradictory even to the seven

statements.

 

Page 229

 

I can tell you many other things, but I

think it best to tell you -- to let you hear it from

the witnesses, from our witnesses as well as Mr.

Fry's witnesses, and his witnesses go first.   But I

ask you to listen carefully to Mr. White, and I know

that you will, observe him carefully, because in

order to return a conviction in this case, you have

got to believe everything that he says.

Ultimately this jury, as any other jury

who sits in Tuscaloosa or my little town of

Summerville or New York or California or over in

Mr. Fry's county of Limestone, it's the same story,

it's the same America.  We are looking for the same

thing.  You owe me nothing, you owe Mr. Fry nothing,

you owe it all to the system, and although it may be

an inconvenience for you to be here, there is

nothing any more important than having sensible,

intelligent, upright men and women who stand ready

to meet the challenge of preserving probably one of

the finest things that many wars and the blood of

many Americans has institutionalized, and that's

the fact that in this great nation, and it is a

great country, you can't take away a second of a

person's liberty or a dollar of their money, except

 

Page 230

 

with the unanimous verdict of this jury.   And

ultimately you are not responsible for the

consequences of your verdict, you are only

responsible for the truth of your verdict.   I ask

you for no more.  My good friend, Jack Drake, that I

am delighted to be here with, and Mr. Hooper and Mr.

Sandlin, would not ask you for any more, nor expect

any less.

And I thank you for your kindness and

attentiveness in listening to my short opening

remarks.

Thank you, Your Honor.

THE COURT: Ladies and gentlemen, it's

about lunchtime.  So we will be recessing for

lunch.  Please go into the jury room at this time

while the bailiffs make arrangements to take   you  to

lunch.  Everybody remain seated until the jury has

reached the jury room.

(Brief pause.)

THE COURT:  Court is in recess until 1:00

p.m.

 (Whereupon, proceedings were in recess at

11:50 a.m., until 1:07 p.m., at which time the

following occurred:)

 

Page 231

 

THE COURT:   Mr. Pry, are you ready?

MR.  FRY:  State is ready, your Honor.

THE  COURT:  You gentlemen ready?

MR.  DRAKE: Yes, Sir.

THE  COURT:  Do you have some witnesses?

Are there any  witnesses in the courtroom? And, if

so, they need  to be sworn and put under the rule.

MR. HOOPER: Judge, we are going to

invoke the rule, too.

THE COURT: Right. Are there any

witnesses in the courtroom that are going to

testify?   If so, all of the witnesses that expect to

testify in this case, stand and raise your right

hand.

(Witnesses sworn.)

THE COURT:   Okay.   Now, the rule is

invoked, which means that all of the witnesses have

to go outside and wait until you are called to

testify.  With the -- I understand that you

gentlemen probably have some exceptions that you

want to make?

MR. DRAKE: We don't have any. Mr. Fry

said he wanted Mr. Brantley excepted from the rule,

and I don't know of any reason why he should be

Page 232

 

unless

MR. HOOPER:  The only agreement we have

had, Judge, is Mr. Morgan and his wife and Doug

Martinson.  That's it.  Everybody else is out.

THE COURT:  All right.  Come around.

MR. HOOPER:  Of course, Mr. Miller, when

his client is in here, we would expect him to be in

here.

THE COURT:  Well, he is in the same

category as an officer of the court, as Mr. Morgan

and your law partners.

MR. HOOPER:  But this is our agreement

between Mr. Pry and myself.

THE COURT: Okay. To exclude

MR. HOOPER:  Those persons named

THE COURT:  What about Mr. Miller?

MR. HOOPER: No, sir, that's not --

MR. MILLER: Judge, I'm in a little

unique situation, in that my client is   additionally

and still remains charged with capital   murder, and

in defense -- in his defense I think it behooves me,

in representation of him, to remain at   least for

portions of the testimony that's to be   given, other

than that given by him, and additionally, Your

Page 233

 

 

Honor, I know nothing about the case, anyway, that

I could testify to or know of no reason I would be

subpoenaed by the defense.

THE COURT:  Well, what reason do you --

MR. HOOPER:  Judge, we have got more than

one reason -- of course, he made many statements to

the television about his client and his client's

participation in the crime. We expect to examine

him on that.  We expect Mr. Miller also to repeat

THE COURT:  I don't believe that's

necessarily admissible, Mr. Hooper.

MR. HOOPER:  Judge, it may not --

THE COURT:  You can't just gather someone

in and decide -- if so, everybody in the courtroom

would probably be subject to testifying.

MR. HOOPER:   Mr. Miller, I assume, has

talked with his client. We expect to examine his

client on those conversations that Mr. Miller later

made public comment on, in addition, Mr. Miller was

on television stating about his client being con-

wise, to insinuate he would know how to work the

system.   So we certainly think that Roy is a bona

fide witness.

MR. DRAKE:   He certainly participated in

Page 234

 

MR. DRAKE: He certainly participated in

 

the preparation and approved the plea agreement,

which is going to be admitted into evidence.

THE COURT: Well, he is going to be present

in the courtroom during that testimony, too. He will be present in the courtroom during the testimony.

All right. Mr. Miller, go outside. The rest of you ladies and gentlemen that are under the rule will have to go outside.

MR. FRY: Your Honor, we would ask that

Investigator Brantley, who was the chief investigator and representing the agency that made the case, be excused.

THE COURT: He is excluded from the rule. And

the gentlemen that you had those -- that you had

the agreement concerning, are also excluded from

the rule. Okay.

MR. HOOPER: Judge, we have also subpoenaed

Mr. Brantley ourselves.

THE COURT: He is excused from the rule.

MR. HOOPER: We object.

THE COURT: Mr. Fry, you may call your first

witness. Excuse me. We have got to have a jury, don't we.

Page 235

 

MR. FRY: I'll be happy to, Judge.

THE COURT: It's been a long day already.

MR. FRY: Yes , sir.

MR. COOK:  From time to time I have a

hearing impediment in my left ear.  If I find it

necessary, would the Court object if I put my chair

at the end of this table?

THE COURT:  Not at all.

MR. COOK: Thank you, Your Honor.

THE COURT: Bring the jury out.

(Brief pause.)

THE COURT: Mr. Fry, your first witness.

MR. FRY:  Officer Dunnagan, Jimmy Dunnagan.

JIMMY DUNNAGAN

being first duly sworn, was examined and testified as follows:

DIRECT EXAMINATION

BY MR. FRY:

Q    State who you are and what you do,

please, sir.

A    My name is Jimmy Dunnagan. I'm a police

officer with the City of Huntsville.

Q    You may want to pull that mic up just a

 

Page 236

 

 

little bit to make sure the jury hears you.     I can

barely hear you back here.

How long have you been with the City of

Huntsville?

A     Approximately six and a half years.

Q     What did you do for them?

A     I'm a uniform patrol officer.

Q     Is that what you have done the whole six

years you  have been with them?

A     Yes, sir.

Q     Are you married?

A    No, sir.

Q     Are you from Huntsville?

A     No, sir.

Q     You from Tuscaloosa?

A     Yes, sir.

Q     You visiting folks while you are down

here?

A     Some, yes, sir.

Q     Trying to.  Well, back in the spring of

last year, that is, more particularly May of last

year, were you a Huntsville police officer then,

also?

A    Yes, sir.

 

Page 237

Q     Back more particularly on one Friday

night, on May 22nd of last year, were you working

then?

A     Yes, I was.

Q     What shift were you working; do you

recall?

A     I was working 2:30 to 10:30.

Q     2:30 in the afternoon?

A     Yes, sir, 2:30 p.m. to 10:30 p.m.

Q    Something unusual happen that night?

A    Yes, sir.

Q     Did you get a call before going of f that

evening?

A     Yes, sir, I did.

Q     You would have gotten off at 10:30; is

that right?

A     Yes, sir.

Q    Did you get a call telling you to go over

to Boulder Circle?

A     Yes, I did.

Q    When did you get that call?

A    It was approximately 9:30 p.m.

Q     9:30 at night?

A     Yes, sir.

Page 238

 

 

Q     And do you remember where you were when

you got the call?

A     Yes, sir, I was on Redstone Road near

Memorial Parkway.

Q     What did you do?

A     I proceeded immediately to the location

at 2700 Boulder Circle.

Q     Did you know why you were going over

there?

A     I was dispatched to a burglary in

progress,  where the victim was reportedly injured

inside.

Q     All right.  How far was it, Jim, from

where you  were on the Parkway -- remember this jury

nay not be real familiar with Madison County o ,r the

Parkway    How far was it from where you were to the

address where you had to go?

A     Approximately eight miles.

Q     How long did it take you? When did you

get there?

A     It took me approximately five to six

minutes to get there.

Q     And what part of Huntsville is that in,

directionwise, south, west, east?

Page 239

 

 

A    I'm sorry?

Q    What part of Huntsville is that in?

A    Redstone Road is in South Huntsville.

Q    All right.

A    Boulder Circle is in southeast

Huntsville.

Q    So you were going to southeast

Huntsville?

A    Yes, sir.

Q    Where did you go to?

A    I went to 2700 Boulder Circle.

Q    What kind of neighborhood is that?

A    It's a fairly exclusive neighborhood.

Q    By that, what do you mean?

A    Mostly doctors, lawyers, professional-

type people live in that area.

Q    Had you patrolled that area before or

been in that neighborhood before?

A    Yes, sir.

Q    All right.  Was anyone with you or were

you by yourself?

A    I patrol by myself.

Q    And when you arrived at the scene, was

anyone else there?

Page 240

A    Yes, sir, Officer Wayne West and I

 

arrived at the scene approximately the same time.

Q    What did you all do when you got there?

A    We observed the front of the house,

checked for any type movement inside the house, and

we started approaching the house.

Q    I believe you testified you had been told

there could be a burglary in progress; is that

correct?

A    Yes, sir.

Q    Based on that information, did you take

some kind of precautions?

A    Yes, sir. Officer West and myself both

pulled our firearms, and we had those available as

we approached the house.  We approached it with

caution.  Officer West came from the right side of

the house, I came from the left side of the house.

Q    What kind of house was that?

A    It was a two-story brick house.

Q    Big house?

A    Yes, sir.

Q    So you came from one side and Officer

West came from the other side?

A    Yes.

Page 241

 

 

Q    Did you see anybody else other than the

two of you?

A    There was HEMSI or the ambulance

personnel was out front.    I believe there was a

couple of neighbors out a ways away from the house.

Q    All right.  A little ways away from the

house, is that what you are saying?

A    Yes, sir, approximately two, three houses

down.

Q    Two or three houses down?

A    Yes, sir.

Q    So what did you do?

A    As we approached the house, I noticed the

light on in the garage downstairs.     I advised

officer West.   We went in and checked the garage

area first and we located no one there.     The door

leading from the garage to the upstairs area was

locked, so we come back around the front, and we

entered the front of the residence and made a room-

to-room search of the residence.

Q    Front door was opened?

A    Yes, sir, the front door was opened.

Q    Was it unlocked or was the door actually

ajar or open?

Page 242

 

A    The door was actually opened

 

approximately  b a I f w a y

Q    All right.  So the door was not locked?

A    No, Sir.

Q    And you went in the front door?

A    Yes, Sir.

Q    After going in, I believe you said you

went from  room to room. What do you mean by that?

A    Because the call came out as a possible

burglary in progress, we were checking each room as

we went through to ensure that no one was there in

the residence or to locate anyone that was there.

Q    okay.  Did you go into each room of the

house?

A    Yes, Sir, we did.

Q    And how many stories does that house

have?

A    It has the basement level with the garage

and then two floors.   First floor ground level,

then a floor above that.

Q    So your testimony is either you or

officer West went into each room; is that right?

A    Yes, Sir.

Q    You weren't with him, I take it?

Page 243

A   We had visible contact with each other.

Q   Okay    So did you work as a team, more or

1ess?

A   Yes, sir.

Q   Now, did you find someone in the house?

Did you find a body in the house?

A   Yes, sir, we found a body in the house.

Q   After you had made your search, did you

find  any living people in the house?

A   No, sir, we did not.

Q   Did you find an intruder?

A   Pardon?

Q   Did you find someone who didn't belong

there?

A   No, sir, we found no one other than Dr.

Wilson.

Q    Where was he found?

A    He was in the upstairs hallway, partially

in the hallway, partially in a bedroom door.

Q   Would that be on the second story of the

house or the third story from the ground?

A   Yes, sir.

Q   If we call the basement the first story,

then that would have been the third story; is that

 

Page 244

right?

A    Yes , sir.

Q    Were you and Officer West together when

you discovered  Dr. Wilson?

A    Yes, sir.  I was proceeding up the

stairwell just   ahead of Officer West, who was

covering me as  I was proceeding up.

Can you describe the way   you got to the

second story?   Is there stairs or --

A    There is a staircase that comes from the

first floor or the ground level to the top floor .

Q    All right. At what point in time going

up the stairs, if at all, were you able to see Dr.

Wilson?

A    I was approximately four to five steps

down from the top.

Q    How tall are you?

A    Five-eleven.

Q    So before you would have got to the top

of the  stairs you could see what?

A    I could see someone laying in the hallway

or on the floor.

Q    Now, at that time had you cleared the

third floor?

Page 245

 

 

A     No. sir.

Q     So this is when you first go to the third

story, then; is that right?

A     Yes, sir.

Q     What did you and Officer West do?

A     We surveyed the top floor to see if there

was any movement up there.   We watched the subject

laying on the floor to see if there was any movement

there.  We saw none, so we finished clearing the

upstairs rooms by a room search of each room. We

then -- finding no one there, we advised the

ambulance personnel to come in and check the

subject.

Q     Okay.  The ambulance people had been

waiting outside during this time you cleared the

house; is that right?

A     Yes, sir.

Q     Was anyone in the house other than you

and Officer West until you called for the ambulance

people?

A    No. sir.

Q    Are they paramedics or some kind of

rescue people?

A     Paramedics.

Page 246

 

Q   Did they examine Dr. Wilson?

 

A   Yes, sir, they looked at him.

Q   Now, did you know Dr. Wilson?

A   No, sir, I did not.

Q   Was he identified to you as Dr. Jack

Wilson?

A   Not at that time, no, sir.

Q   Was he later on?

A   Yes, sir.

Q   Did you learn that was who the gentleman

was?

A   Yes, sir.

Q   Were the HEMSI -- which stands for what,

Huntsville Emergency Service?

A   Medical Service.

Q   Medical?

A   Yes, sir.

Q   Were they able to do anything to help Dr.

Wilson?

A   No, sir, they were not.

Q   Would you describe the condition he was

in or his appearance as you saw it?

A   There was a head injury, there was

noticeable -- it appeared that his left arm had

Page 247

been broken, and there were like two puncture

wounds in his shirt that I could see.

Q    Was he dead?

A    Yes, sir.

Q    Did you witness any kind of weapon or any

kind of instrument around or about Dr. Wilson's

body?

A    Yes, sir.  There was a baseball bat near

the body.

Q    Did you -- or what did you do after the

emergency  people arrived and began looking at Dr.

Wilson's body?

A    Once they advised that he was dead and

there was nothing they could do for him, officer

West and I directed them out of the house.    I

notified dispatch that we needed a sergeant and

crime scene and homicide investigator to respond to

the area.  Officer West and I then secured the

house.

Q    And by that, what do you mean exactly?

A    We stood in front of that house to

prevent anyone from entering the residence or

leaving the residence.

Q    And how long did you perform those

Page 248

 

duties?

A    I was there for approximately two, two

and a half hours, I believe.

Q     All right.  To prevent anyone other than

authorized people from coming or going, is that

what you said?

A     Yes, sir.

Q     Policemen?

A     Police investigators.

Q     Okay.  And you notified the homicide

unit?

A     I notified dispatch and had dispatch to

notify the shift sergeant, crime scene investigator

and homicide.

Q     All right.  So in Huntsville, then, do

you have two separate police departments, all part

of the police department, one that actually works a

homicide case as detectives and another agency that

actually works the scene?

A     Yes, sir.

Q     And they both were notified?

A     Yes, sir.

Q     Did anyone do anything to move anything

that you saw or tamper with anything in the house

 

Page 249

from the time you arrived until after you had

established your security?

A     No, Sir.

Q     Did the medical people do anything; did

they try to move Dr. Wilson's body or did they try

to start an IV or do any kind of medical procedure

on him?

A     No, Sir.

Q     As far as you know, was he moved at all

from the time you saw him?

A     No, Sir, he was not moved.

Q     Jim, one last question.  And I have got

to ask you for the record, even though we are in

Tuscaloosa.  Was his body in Madison County,

Alabama?

A     Yes, Sir.

Q     2700 Boulder Circle is in Madison County?

A     2700 Boulder Circle, yes, Sir.

Q     And that's where you saw Dr. Wilson's

body?

A     Yes, Sir.

MR. FRY:  I believe that is all.  I'm sure

these gentlemen will have some questions for you.

MR. HOOPER: Officer, I have just got a [few questions?]

Page 250

 

CROSS-EXAMINATION

 

BY MR. HOOPER:

Q     When you arrived on the scene and after

you had gone through the house, I believe you

stated that you had instructed the HEMSI people to

come in; is that correct?

A     Yes, sir.

Q     Where were you in the house when you told

them to come in?

A     I came out to the front door and motioned

for them to come in.

Q     Okay.  Was there any other police officer

inside the house besides yourself at that time?

A     Officer Wayne West.

Q     Where was he?

A     He came out with me.

Q     Okay.   Did you accompany the HEMSI people

back upstairs to where Dr. Wilson was?

A     Yes, sir, we did.

Q     Do you remember the HEMSI people or one

of the HEMSI paramedics, either kicking or tripping

on the ball bat?

A     I don't recall, no, sir, I don't.

Q     You are not saying it didn't happen, you

Page 251

Q    You are not saying it didn't happen, you

just don't recall it?

A    Yes, sir.   I don't know if it happened or

not.  I didn't see it.

Q    Okay.  Well, when you first got there and

went  upstairs, you saw the position of the ball

bat,  did you not?

A    I saw it, yes, sir.

Q    And where was the position of the ball

bat?

A    I don't know the exact -- I don't

remember the exact position.     I knew it was near the body, but I was more interested in checking the

house for other people.

Q    Okay.   After you accompanied the HEMSI

people upstairs, did you go back downstairs with

them?

A    Yes, sir.

Q    Did you ever have any opportunity to go

back upstairs?

A    I went back upstairs one time when Sgt.

Giles responded to the location.

Q    Did you notice whether or not the

position of the ball bat had changed?

Page 252

 

A     No, sir, I didn't notice the position of

the ball bat.

Q     If you would, please, sir, did the HEMSI

people ever go -- actually go to the body and touch

it?

A     Yes, sir.

Q     They actually touched it?

A     Yes, sir, I believe so.

Q     Do you remember that?

A     I believe they did.

Q     You believe they did or they did?

A     I believe they did.  I'm not sure.

Q     Okay.  Around the body itself there was a

pool of blood; is that correct?

A     I don't recall seeing a large pool.

There was blood around the body, yes, sir.

Q     Okay.

MR. HOOPER:  Have you got the crime scene

photographs?

MR. FRY: Yeah.

(Brief pause.)

Q     officer, if you will, look at what's been

marked -- actually it's State's Exhibit P-1.    Can

you identify that?

Page 253

 

A    Yes, sir.

Q   Is that the small pool of blood that you

saw, please, sir?

A   Yes, sir.  As far as I can remember it,

yes,    sir.

Q   Pretty good size pool of blood, right?

A   Yes, sir.

Q   At the time you walked over there to the

body, did   you step in the blood or did you get in

the vicinity of the blood with your shoes?

A   I don't think so, no, sir, I don't.

Q   Do you recall the HEMSI ambulance

paramedic  stepping in the blood itself?

A   I don’t recall.   It's possible.   They

were more to the right of  him, facing this picture.

Q   Did you also see a palm print in the

blood?

A   Yes, sir, I saw a palm print.

Q   Where was the palm print?

A   I don't recall exactly where it was.

Q   But it was even visible to you at that

time; is that correct?

A   Yes, sir.

Q   All right.   Officer, I think you stated

Page 254

 

 

that you were about -- you were four to five steps

from the top; is that correct, when you saw the

blood?

A    Yes, sir, somewhere in that vicinity.

Q    And you have a good recollection of that;

is that correct?

A    Yes, sir.

Q    Could you have even been further away,

maybe five or six steps away?

A    It's possible.   I know when my eye level

came -- when my eyes came level with the floor, I

could see someone laying there.

Q    You sure it was at least four to five

steps away or maybe more?

A    Maybe more, yes, sir.

Q    Officer, do you recall whether or not

there was a landing on that stairwell?

A    I believe there was.   I'm not positive

about that.

Q    Okay. officer, as you went up the

stairwell, how did you go up there?    I assume you

didn't know whether or not there may still be an

intruder in the house, so you were taking some

measures to protect yourself?

Page 255

 

 

A   Yes, sir, I had my weapon drawn.

Q   Did you go up maybe with your side,

sideways up the stairwell or just --

A   Yes, sir.   The stairwell sort of curved

back to the left, and Officer West was down at the

bottom of the stairs as I started my assent,

covering in case somebody looked over.    And I

walked at an angle so I could see the upstairs

hallway as I was going around.

Q   So you were making a determined effort to

try and see, as best you could, as to what was on

that other upper level; is that correct?

A   Yes , sir.

Q   If you would, officer Dunnagan, look at

Defendant's Exhibit 1.   Can you identify that?

A   Yes, sir.   That appears to be the Wilson

house.

Q   Okay. Well, that's actually the

stairwell, is it not, not the house?

A   Yes, sir.   I'm sorry, the stairwell.

Q   Okay. And look on the back side of it,

please, sir.  Again, does that not depict the

stairwell area of the home?

A   Yes, sir.

Page 256

 

Q    Basically, the first and second floor; it

that correct?

A    Yes, sir.

Q    All right.  If you would, please, sir, on

one of the photographs -- right here, on the first

page, the second photograph, can you also note how

many steps are from the landing actually to the

second floor?

A    From the landing to the second floor

appear to be about three.

Q    Three steps.  So actually you were down

on -- you hadn't even gotten to the landing and you

could see the body; is that correct?

A    Yes, sir, somewhere in that area.

Q   Okay.  officer, I would ask you, if you

would, please, sir, mark about where on this first

flight of steps, where you were when you first

observed the body.

A   Based on the photographs and everything,

I was probably right here on this landing area,

right in here or maybe the step below.

Q   Well, you said four to five steps,

possibly more.  So we have got three here, there

would be four steps here, five and six.  So just

Page 257

 

 

bracket where. you would have been.

A     I would say approximately the fourth step

down . The step before you get to the landing.

Q     All right.  So you are not five or six

steps ,you are four steps?

A     Yes, sir, it appears that way.

Q     You have a good recollection of that now?

A     Yes, sir, after looking at the

photographs it's come back a little bit.

Q     You hadn't seen the photograph prior to

today?

A     No, sir.

MR. HOOPER:  We would offer Defendant's

Exhibit I.

THE COURT:  Any objection?

MR. FRY: No objection.

THE COURT:  Defendant's Exhibit I is

admitted.

Q     Officer, when you first got to the home,

did you pull up and stop in front of the house or

did you go in the driveway or where?

A     We pulled up approximately one house

before you get to the residence.

Q     Okay.  Did you see any lights on in the

Page 258

 

 

house at that time?

A     Yes, sir, I did.

Q     What lights did you see on?

A     Appeared to be a hallway and a stairway

light.

Q     In fact, was that the only lights on in

the house?

A     There was also a light on in the garage

downstairs.

Q     So three lights; is that correct?

A     Yes, sir, and I believe there was one

small light in the kitchen that was left on.

Q     Did you go behind the house, that is, to

the rear of the house?

A     We checked the rear, yes, sir.

Q     Okay.  Did you have an occasion to check

the yard that night?

A     No, sir.

Q     What was your furthest most point that

you went from the rear of the house?

A     Probably the corner of the house.

Q     Just the corner?

A     Yes, sir.

Q     Did you discover any long hoses or any

Page 259

 

apparatus of that type laying about in the back

yard or in the front yard?

A     No, sir, I wasn't paying attention to

anything like that.

Q     Could have been there, you just don't

remember seeing them?

A     I wasn't looking for them, so I don't

remember.

MR. HOOPER:  No further questions.

THE COURT:  Any more questions, Mr. Fry?

MR. FRY:  Your Honor, I have no further

questions.  This is an on-duty officer in

Huntsville and we would ask that he be excused.    I'm

sure he could be re-called, if he is needed in

rebuttal or something.

MR. DRAKE:  We don't have any problems

with that.

THE COURT:  Mr. Dunnagan, you may be

excused. Next.

MR. FRY:  We call Investigator Glen

Nunley.

GLEN NUNLEY

being first duly sworn, was examined and testified

as follows:

Page 260

 

 

 

DIRECT EXAMINATION

BY MR. FRY:

Q     If you will , please tell the ladies and

gentlemen of the jury who you are and what you do,

please.

A     My name is Glen Nunley and I'm an

investigator with the Huntsville Police Department.

And my job pertains to the crime scene. That's

photographing, taking fingerprints, collecting

evidence.

Q     How long have you been in law

enforcement, Glen?

A     Over 13 years now.

Q     Have you always been with Huntsville?

A     Yes, sir.

Q     Are you from Huntsville?

A     Yes, sir.

Q     Married?

A     Yes, sir.

Q     Kids?

A     Yes, sir.

Q     Were you with the crime scene

investigation unit back in May of last year?

A     Yes, sir, I was.

Page 261

 

Q     Were you called sometime on the 22nd to a

home there in Huntsville to work a crime scene?

A    Yes, sir, I did.

Q    What was the nature of the work that you

did there?

A    Well, I arrived on the scene, Officer

Dunnagan and Officer West showed me through the

house and gave me a quick once-over of what they

had. I looked it over, I started taking

photographs, started drawing diagrams, and taken

later determined what we would be collecting as

evidence, and so on.

Q    Okay.  Now, the house you are referring

to, was that 2700 Boulder Circle?

A    Yes, it is.

Q    Let me show you two State's Exhibits

marked P-13 and P-14, and ask you if you can

identify those exhibits.

A    Okay.  P-14 is a photograph I took of the

residence when I first arrived that night. And P-

13 is a photograph showing the number on the

mailbox with the house in the background.

Q    Did you take these photographs?

A    I took the one of the front of the house.

Page 262

 

I didn't take the one of the mailbox,that was taken

while I was there.  I was doing the videotape when

they took that picture.

Q   But is that the house in the daytime, and

you took the picture at night?

A   Correct.  Yes, sir.

MR. FRY:  We move State's Exhibit P-13

and P-14 into evidence.

MR. HOOPER:  No objection.

Q    Now, Glen, what kind of crime scene' was

it you all were processing when you got there?

A   It was a burglary in progress and there

was a -- the deceased person was still on the scene,

so a murder.

Q    Is that the way it was called in?

A   Yes, sir, I believe it was called a

burglary in progress.

Q   All right.   Now, in working the crime

scene, do you, as a part of what you do, make a

diagram of the place in which the apparent crime

occurred, that is, in this case, the house?

A   Yes, sir.

Q   Did you do that in this case?

A   Yes, sir.

Page 263

Q    You did that personally?

A    I did that with Investigator Hutchinson's

assistance.

Q    Okay.  Well, did that include making

measurements and going through the entire house

room by room?

A    Yes, it did.

Q    In this case did you get a floor plan or a

diagram of the house at some point?

A    We got that later to assist us in drawing

it out.

Q    Kind of helped, I guess?

A    Yes, Sir.

Q    Glen,, I'm going to move this around and,

if you can see it, fine; if not, you can get up, but

I want to make sure that the jury sees it.

MR. PRY:  Your Honor, if I may inquire or

if you will inquire as to if the last people down

there can see.  Nod your head if you can't.    Can

everybody see that? Okay. Fine.

Q    I tell you what, Glen: We are going to

have to do like the weatherman and stand up, and

don't put yourself between this exhibit and our

jury here.  Let's put it where they can see it.

Page 264

 

MR. PRY:  Can you see it, Mr. Cook?

MR. COOK:  Certainly can.   Thank you very

much.

Q    Tell me what this is, Glen.

A    That is the basement of the residence.

Q    All right.  Did you make that diagram?

A    Investigator Hutchinson and I both made

it, yes, sir.

Q    And does it -- what does it represent?

A    There was a bedroom in the basement, a TV

room in the basement, a laundry room, a large

closet, a bathroom, and two-car garage and a large

storage area.

Q    Does it accurately depict the layout of

that house as far as the rooms, stairwell, the

relationship of the rooms to one another?

A    Yes., Sir.

MR. HOOPER: Mr. Fry, we have no

objection on the drawings that you have given us,

as far as the admissibility.

MR. FRY: Thank you.

Q    Is it to scale?

A    No, Sir, it's not.

Q    okay. But is it generally relative to

Page 265

 

the size of the rooms?

A    Yes, sir, it is.

Q   Was that a big house or a small house?

A   A large house.

Q   A large house.   okay.  And did you go

through each room down in the basement, Glen?

A   Yes, sir, I did.

Q   What was the purpose of going from room

to room?

A   To search for any evidence of any kind of

crime, whether it was a burglary or whether there

was any blood downstairs or any other of the

victim's clothing -- just anything and everything.

Q   Did you take any fingerprints?

A   Yes, sir, I did.

Q   And did you take those fingerprints in

the downstairs?

A   Yes, sir, we did.

Q   Let me show you what I'm going to mark --

(Brief pause.)

Q   I show you what I have marked -- you can

have a  seat, I think, for just a minute, anyway --

as State's Exhibit P, as in papa, 15.

MR. COOK:   What was the number, please?

 

Page 266

 

MR. FRY: P-15 or photo 15, Mr. Cook.

THE COURT:  Where did you come up with that

 letter?

          MR. FRY: “P” for photos, Your Honor.

There is going to be a batch of them, and instead of

having 200 exhibits.  And I have already got some already numbered, Your Honor.

     Q    Let me ask you to look at this photo, if you will, Glen.  Can you describe that?

     A    It’s the entrance to the garage from the

outside of the hours, looking towards the house. 

     Q    did you take that photo?

     A    No, sir, I did not.

     Q    Does that represent the outside of the house that have already described the basement

of?

     A    Yes, sire, from the outside looking towards.

     Q    Can you show the jury where this

garage – double garage door would be?

     A    Here were the double garage doors, right

here, and the picture was taken from this angel looking this way.

          MR. FRY:  We offer this as State’s

Page 267

 

Exhibit P-15, Yours Honor.

          THE COURT:  All right, admitted.

     Q    We are going to work from the ground up here, Glen, from the basement up.  This is P-16, and

I ask you if you can identify this photograph.

     A    Yes, Sir.  It’s an area out behind the

house, from here looking this way.

     Q    All right.  Can I get you to do this:

Could you label on the diagram, make an “X” where

This P-17 would be, maybe an “X”, then put P-17 by

It.

          (Witness complies.)

     Q    I think maybe you have it on another diagram.  Put P-17.

     A    Yes, Sir.

     Q    So if you were looking from the back of the house could you see this over there?

     A    Yes, sir.

     MR. FRY:  Offer P-17 into evidence, Your

Honor.

Q    Let me show you what I have marked as P-

18.

     A    Okay.  This is essentially a shot of the

same area.  There was a swimming pool right here and

Page 268

 

 

this shot was taken from about here, looking in

this direction.

     Q    All right.  Look at all those, if you

will, Glen.  This P-18, is that the pool that’s in the back yard of 2700 Boulder?

     A    Yes, sire, it is.

     Q    All right.

          (Brief pause.)

Q    It’s pretty much directly behind the

house?

A    Yes, sir.  These are all in the back of

the house, from the floor above, this deck above

the pool, and then the outside around the back of

the pool.

     Q    Okay.

          MR. FRY:  Your Honor, we move P-18 into

evidence.

          THE COURT: 18 is admitted.

     Q    All right.  Glen, let’s take the rest of

these in order.  I have marked this series of

exhibits P-19 through P-24.  If you will, take them

one at a time and show, using the diagram in the

photograph, where the photograph depicts on your

diagram of this ground floor of 2700 Boulder

Page 269

 

 

Circle.

     A    This is on the floor above this floor.

     Q    All right.  Let’s hold that one out.  I’m

sorry.  Is that a deck?

     A    Yes, sir, a deck on the main floor.

     Q    Okay.

     A    And this shot here is a shot of the

stairway leading down from the deck and to a rock garden or something in this area right over here.

That’s P-20.  And this is a shot of the rock garden,

in that area.

     Q    Would you write that?  You need my pen

again, I guess.

     A    Yes, sir, I do.

     Q    Mark the photograph where the rock garden is.

     A    It’s P-20 and P-21.

     Q    That will be fine.

     A    This is a shot of just the railing on the

back of the deck.

     Q    Would that have been one story up above

the pool or the ground level”

     A    This is up on the main floor level.

     Q    All right.    

Page 270

 

A    And this is P-27.  It’s another shot of

this area over here.  And P-24 is a shot of this

area, right over in this area.

     Q    Are there trees or wooded area there?

     A    It’s just forage.

     Q    All right.

     A    And P-20 is a shot of the stairway going

down to the rock garden.

          MR. FRY:  We move Exhibits P-20 through

P-24 into evidence, Your Honor.

          MR. HOOPER: Let me see 20 a minute.

          (Brief pause.)

     Q    All right.  Did we cover the basement

floor, Glen?  Did you leave any rooms out?  Did we

not talk about any rooms in the basement floor”

     A    Well, there is one bedroom, then a TV

room, and then a two-car garage and a laundry room

and a closet – or two closets.

     Q    And you say the garage is on the left-

hand side as we look at it?

     A    Yes, sir, the garages are right here, and

this is a bedroom, and this is a TV room, and there

was a sliding door or French doors here that went

out into the back area.

Page 271

[STRICKEN FROM THE RECORD] . . . . it  was?

A   I think his name was Trey.

Q    Trey?

A    Yes, sir.

Q    Let's move up one floor.

MR.   FRY:    By  the  way,   Your  Honor,   we  move State's  Exhibit  I,   if  we  haven't  already,   the diagram.

THE COURT:  Any objection?

MR. HOOPER:  No, sir. Judge.  In fact, Jimmy, if you want to go ahead and offer all your diagrams in, that would be fine.

MR. FRY:  Great.  Let's do that.

(Brief pause.)

MR.   FRY:    We  offer  into  evidence,   then, Your  Honor,   State's  Exhibits  2,   3,   and  4.

THE COURT:  Each are admitted, 2, 3, and 4 are admitted.

Q    Let's stay on the second floor for a minute, Glen.  What does this diagram describe?

A    This is the main floor of the house, with this being the front door and this being the deck above the pool which is in the back yard.   

Q    And, again, you made this diagram?

Page 272

Q    And, again, you made this diagram?

A    Yes, sir.

Q    All of these we have here today, either

you or your partner have produced for us for use in this trial?

A    Yes,  sir.

Q    So you actually had this drawn up from your notes and observations?

A         Yes,  sir.

Q    Can you tell us from room to room what the house was like on the second floor?

A    Okay.  You enter the house from the front door, with Boulder Circle being right here, the front door, it faced the dead end of Boulder Circle.  There is a large foyer area, a sitting room over here, had a couch and some chairs, a large dining room over here, the kitchen here, and a library and a small bar right over here.  And, of course, the foyer went all the way through the house to the back deck, and then the stairway leading back downstairs.

Q    If you will, hand me that exhibit on the rail that we had out of order a moment ago.  What exhibit is that?

Page 273

 

A    P-19.

Q   What is P-19?

A    Shows a picture of the deck right here, taken from here.

Q   Do you want to  write  "P-19"  on  the  deck?

A         (Witness  complies.)

Q    So this exhibit, then, P-19, is the deck which is really the ground floor or the second floor?

A       Yes,  sir,  the  ground  floor.

Q       Was there a deck off of the third  floor?

A         No,   sir,  there  was  not.

Q         So  this  is  the  only  deck?

A         Yes,   sir.

MR. FRY: We  offer  P-19  into  evidence.

THE  COURT:     19  is  admitted.

Q    Now, you and your partners worked this second floor of the house, also?

A    Yes,  sir,  we  did.

Q    And what did you do  on  the  second  floor?

A         We  photographed  all  the  rooms,  we

collected evidence from the second floor, and we fingerprinted several items on several surfaces on the second floor.

Page 274

 

Q    Let me ask you to look at this

photograph.  Me are going to mark it P-25.  What is that a photograph of?

A    That's a photograph of the dining room.

Q    And where is that located? A    Right here.

Q   Do you want to put what, "DR," dining room?

A         (Witness  complies.)

Q    All right.  Thank you.  Let me show you, then, what we have marked as State's Exhibits P-26, P-25, and 28.

MR. HOOPER: Do you have a 27?

(Brief pause.)

Q    25, 26, 27, and 28.  Now, can you

identify  those  photographs.  Glen,  with  the  rooms  of the  house?

A    Yes, sir, I can. This is a picture of a broken dish or something that was in  the library. It's located in this corner of the  library  up  here.

MR. HOOPER: Mr. Fry, could you have him give us the number.

A    This is P-26.

Q    Do you want to write it on the room as you

Page 275

go.

A    This is another photograph of the

library, shooting from this area, shooting from back this way, and it’s P-26, also.  P-27 is a photograph of this sitting room up here.  And P-28 is in the dining room.

MR. FRY:  We would move those into evidence. Your Honor, if there is no objection.

THE  COURT:    26,   26,   27,   and  28  are admitted.

MR.  HOOPER:    Mr.  Fry,   I  don’t  believe  you referred  to  25.

MR.   FRY:  25, 26, 27, and 28.

A   Yes,   sir.

(Brief  pause.)

Q   Let’s move  up  to  the  third  floor  there, Glen,   if  you  want  to  change  the  diagrams.

Glen, can you explain for the jury what the layout  was  of  the  upstairs  of  the house.

A       Okay. This was a foyer, the stairway  led up  here and then  made  a  left-hand  turn  until  you were up  on  the second floor of the house here.    And this is a  large  bedroom  over  here, large  bathroom, and a closet.  On this side was two bedrooms and

Page 276

then a small bathroom in between those.

Q    Do you know whose bedrooms those were?

A    Yes.  This was Betty Wilson’s bedroom and this was Dr. Wilson's bedroom over here.

Q    They were across the hall from one another; is that right?

A    Yes, sir.

Q    Do you know whose bedroom the third bedroom was?

A    It was a guest bedroom, sir.

Q    Let me show you State's Exhibits 29 through 34 and ask you to look at those, please,

sir.

MR.   COOK:     State's  Exhibits  29  through what?

MR.   FRY:     34.

MR.   COOK:    Thank  you.

A    State's Exhibit No. 29 and 30 are from the guest bedroom.      

Q    29 and 30?

A    Yes, sir.

Q    Let's write on there, then, so we can

maybe match the numbers with the rooms -- the rooms with the numbers on the back of the pictures.

Page 277

A    (Witness complies.)

Q    Okay.

A    And 31 is a picture of the closet area here from the bathroom.

Q    Whose bedroom was that?

A    This was in Betty Wilson's bedroom.  32 is also in the spare bedroom.  33 is also in there.

Q   Is that - A   And  34.

Q    The room with the double beds is the guest bedroom?

A    Yes, sir.

MR. FRY:  Do you want to see these, Charlie?

(Brief pause.)

MR.   FRY:  I move State's  Exhibits  31  --excuse  me  --  29  through  34  into  evidence,   Your Honor.  29,   30,   31,   32,   33,   and  34.

THE  COURT:  29  through  34  admitted.

Q    Let me show you two more photographs of rooms or at least furniture, and we will play stump Glen here, and see if you can recall where this furniture is located.  If you can't, it’s all right.

Page 278

 

A    It looks like the furniture that was up on the third floor, but I can't be for sure.

Q    Did you make these photographs?

A    No, sir, I did not.

Q    Do you remember this furniture?

A    Yes, sir.

Q    Was it in the house?

A    Yes, sir, it was.

MR. FRY:  We move State's Exhibits 35 and 36 into evidence.

MR.  HOOPER:    Judge,   for  the  --  let  me look  at  it.

(Brief  pause.)

MR. HOOPER:  I don't have any objection.

Q    But this is furniture out of the house?

A    Yes, sir.

MR. FRY:  We move for these.

THE COURT:  35 and 36 admitted.

MR. FRY: Those are all with a P.

Q    Now, Glen, when you got to the house, who all was there when you arrived?

A    Officer Dunnagan and Officer West and people from the ambulance service.

Q    What were they doing?

Page 279

A    They were waiting on me to get there.

Q    Did you go to the location where Dr. Wilson's body was?

A    Yes, sir, I did.

Q    Where was that in the house?

A    Up on the third floor, right at the entrance of the master bedroom upstairs.

Q    Let me show you State's Exhibit No. 37 and ask if you can identify the contents of this photograph.

A    Yes, sir, it's the stairway leading up from the foyer, taken from here, shooting this direction.

Q    We have got the third floor there.  Were those steps the steps coming up?

A    Going up to the third floor, yes, sir.

Q    That's No. 37.  Let me show you, then, No. 38.  And this is P-37 and P-38.  I show you P-38 first.  Can you tell us what that is?

A    It's a picture of this landing area right here.

Q    Okay.  So there is a landing and a stair that turns and goes up; is that right?

A    Yes, a landing there and you turn left

Page 280

 

and go back upstairs.

Q    Then, let me show you P -- I think it's 37.  What is that a picture of?

A    That's this shot, shooting here.

Q    Can you see this piece of furniture in that picture?

A    Yes, sir, you can.

Q    This is a landing and is the landing visible?

A    At the top of this stairway.

Q    At the top of the stairway?

A    Yes, sir.

Q    Did  you  make  these  photos  or  were  you there?

A    I  made  these  photos.

Q    Is this the condition that the items on the stairway were found -- were they present there when you made this photograph?

A    Yes, sir, they were.

Q    Is that the way the things were?  Had anything been disturbed?

A    No, sir.  Everything was as is there when the police officers arrived.

Q    All right.  I show you one more and I'll

 

Page 281

mark this as P-38, photograph P-38, and ask if you can identify that and show the jury, if you will, where this would be in the house plan.

A    Okay.  It's on the floor beneath this one.

That's an area going into the dining -- the library.

Q    Okay.

A    The foyer shot right in front of the library.

Q    Where do these stairs go?

A    This is a stairway right here.

Q    Does that stairwell connect to this stairwell?

A    That's the same one. Q    Same one.  Okay.

A         It's  just  shot  like  over  here.

Q         One  is  looking  directly  up  and  one  is from  the  side;   is  that  right?

A    Yes, sir.

MR. FRY:  We move State's 37, 38, and 39 into evidence. THE COURT:  Any objection?

MR. HOOPER:  No, sir. THE COURT:  37, 38, 39 admitted.

Page 282

 

Q    I want you to hold onto one just a minute there.  Have a seat. Glen.  What exhibit is that that you have in your hand there?

A    37.

Q    P-37.  What is that a picture of?

A    it’s a picture of the stairway leading from the foyer on the main floor, leading up into the third floor of the house.

Q    And what are those articles. Glen?  Let me ask you this:  What did you see, what does 'that picture depict as far as articles on that stairway?

A    Well, there is a woman's purse, and it appeared as if the contents of the purse were spilled out on the stairway.  There is a set of keys, a wallet, some paper, and two clothing bags like from a department store.

Q    Did they have clothes in them?

A    Yes, sir, they did.

MR. FRY:  Move State's Exhibit P-37 into evidence. Your Honor.

THE COURT:  I believe 37 is already in.

MR. FRY:  I'm sorry, it's already in.

Q    Glen, what was the -- did you make an examination of Dr. Wilson's body?

 

Page 283

A    Yes,  sir.

Q    Did you make some photographs? A    Yes, sir, I did.

Q    What were your observations?  What did you see?  Can you describe his condition or his appearance at the time you saw him?

A    He was laying on his back, his hips were sort of twisted to the right, his right arm was down at his side, his left arm was extended out and up away from his torso.  And his head was turned .to the left.  And he was laying in the doorway, his feet were in the doorway to the large bedroom, and most of his legs and his upper torso and his head was in the foyer upstairs.

Q    Let me show you what has been previously marked as State's Exhibits P-l through P-12.

MR. FRY:  Let me let Mr. Hooper see these.

(Brief pause.)

MR.  HOOPER:    Judge,   I  don't  have  any objections  to  P-l  through  12.

Q     Let  me  show  you  P-l  through  P-ll,   first.

MR. FRY:  And we move these into evidence, Your Honor.

Page 284

THE COURT:  1 through 12 are admitted.

Q    Let's begin with the one on top there, if you will.

MR. FRY:  Your Honor, these are graphic. We wish to publish these to the jury and I want the jury to know these are gruesome photographs.  I don’t want to shock anyone or alarm anyone.

Q    If you will, describe to the jury by using the photographs the injuries which you described a moment ago in your testimony. Glen. You may want to stand up and hold the picture up where they can see it.

A    The doctor was laying on his back, and you could see several injuries to the top of his head.  You can tell that his left arm and his right arm both have been broken in several places.

MR. HOOPER:  Judge, I object to the

officer describing as to what was broken.  I don't believe he has laid a predicate for the officer --

THE  COURT:     Sustained.

Q    Unless you saw X-rays, Glen, just describe the injury, not what you thought the injury to be, but what you, as a policeman, saw, not the diagnosis, but how it appeared.

Page 285

MR. HOOPER:  Judge, the pictures speak for themselves and are introduced.

MR. FRY:  I'm asking him what he saw, and I'm asking him to use the photograph to explain what he saw, if he can do that, but I'm asking him for what he saw, not just what the picture showed.

THE  COURT:     Proceed.

A    He was laying on his back.  You could see several injuries to his head, you could see that his arms were injured and you could see two cuts on the shirt that he was wearing in the area of his abdomen, and blood was all over the floor, he had a bruise or had a red mark on his neck.

Q    You think it was a bruise?

A    Yes, sir.

MR. HOOPER:  Judge, I object to what he thought.

Q    If you will, orient the jury. Glen, as far as where Dr. Wilson's feet are and where his head is in this picture.  Whose room, in other words, are his feet in?

A    His feet were inside this room here,

about where the letter "B" is, and his head is where the letter "A" is.  And this is the master bedroom,

Page 286

this is Betty Wilson’s bedroom.

Q    Let’s put "BW" on there so that they can mark that as her bedroom.

A    (Witness complies.)

Q    All right.  Is his bedroom across the hall, did you say?

A    Yes, sir, right here.

Q    Okay.  All right.  Let's take the next

one. Glen.  Again, orient us, if you will, as to the picture.  What room or what part of the rooms 'are portrayed in that photograph?

A        This  is  another  photograph  of  the  body, shooting  from  this  direction,  looking  towards  the body,  and  it  shows  the  entrance  into  this  bedroom-and  a  small  piece  of  the  foyer  here.

Q        Hold  it  up  so  they  all  can  see.

A         (Witness  complies.)

Q         Where  would  the  door  facing  be  in  that photograph  on  the  diagram?

A    The door facing that's behind his hip is right there.

Q    All right.  Which way would the rug be running, then, that's in that photograph?

A    The rug runs this way.

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Q    Parallel with the stairs?

A    Yes, sir, along that aisle.

Q    All right.  Let’s look at P No. 3, again. I ask you to orient and let the jury see the photograph so they can orient the photograph with the diagram.

A    This is a shot taken from here, looking in this direction.  So it's actually an upside down photograph from this diagram.

Q      Okay.   Let me ask you before we give it to the jury, where in that direction would someone be coming from, coming up to the top of the stairwell.

A    They would be here at the north end of the house, walking towards the south.

Q    Okay.  And on this photograph, from which direction would they be coming, the bottom?

A    Yes, sir, they would be coming from the bottom.  This is the top of the landing, is right here, and then you come to the top of the stairway right here and you walk that way.

Q    As you came up to the top of the stairs, would there be a point in time that your head would be above the top of the stairs?  Is that what you would see as you walked up the stairs?

 

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A    Yes, sir.  As soon as you got to the top of the stairwell, that's where you would be.

Q    Looking down the rug you would have seen Dr. Wilson?

A    Yes, sir.  Standing here, this photograph was made shooting this direction.

Q    Okay.  This is photograph No. P-4. Again, if you will, orient us as to where that photograph was taken from.

A    Okay.  This photograph was taken from the bedroom here, shooting out into the foyer area there at the top of the stairway, just in this doorway area.

Q    Again,  whose  bedroom  is  this  that  Dr. Wilson's  feet  are  in?

A    This is Betty Wilson's bedroom that his feet are in, just inside the door, and then his body extends out into the hallway.

Q    All  right. I believe  you  have  got

something new in this photograph.  What's  depicted in this photograph -- and this, for the record,  is P-6.

A   All right. It shows a bat that's sitting here in the hallway, a note, a broken watch, which

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is right there.  And then Dr. Wilson laying there.

Q    All right.  Now, do you know if anyone moved the bat or did anything to the bat while you were there?

A    The police officer reported that's the way it was when they got there and that's how it was when I got there.

Q    Did you or anyone else in your presence move it?

A    No, sir.

Q    Do you remember. Glen, in your best judgment -- it may be difficult to tell in the photograph -- how far the bat actually was from Dr. Wilson?

A    I think it was about five feet.

Q    I show you what has already been marked and is in evidence as State's Exhibit P-5, and ask if you can describe what injury, if any, you saw which is depicted in this photograph.

A    The reason I took this photograph is

because it showed a bruise on his neck and a button on his shirt had been broken.

Q         All  right.    You  are  talking  about  this red  chafing  look  or  --

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A    Yes, sir, right there at the Adam's apple.

Q    At the Adam's apple.  And this is P-5.  I show you what's been marked as State's Exhibit No. P-7 and ask if you can describe that photograph or what you saw depicted in that photograph? And, again, relate it to the diagram.

A    Okay.  This is a wide-angle shot of Dr. Wilson's body laying there, and it shows where his glasses are, his left arm extended there, him in the doorway and the bat behind him and the note up there.

Q    This photograph -- you say "glasses." Are you indicating the bottom –

A    The bottom of his hand.

Q    -- of his hand?

A    Yes, sir.

Q    His outstretched hand.  Okay.  The bat is back behind?

A    Yes, sir.

Q    Now, Mr. Nunley, in this photograph, P-7, can you tell us what this was on the bottom of --the bottom of the baseboard or the inside of the door facing where Dr. Wilson's body was?

 

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A    That was a large blood splatter.

Q    So in this picture, this red substance here going up to here in the photograph, that was blood?

A    Yes, sir.

Q    Now, the photograph doesn't go all the way up to the ceiling, obviously.  Was there any --did you observe any blood spattering above the height that is depicted here in the photograph?

A    Yes, sir, minute amounts of blood were splattered on the wall up above that.

Q    Is that some there?

A    Yes, sir.  It was just real small,

speckled. You can barely see  it  in  the  photograph.

Q   P-8,  again, if you will, relate  what  you saw  as  depicted  in  that  photograph  and  relate  it  to the  diagram.

A    Okay.  This is another shot, a wide-angle shot, that was taken from about here, shooting in this direction, that shows Dr. Wilson’s body there in the doorway and his body there in the hall.

Q   P-IO.

Q  P-IO is a  wide-angle  shot  that  was  taken from right here, at the top  of  the  stair  --  well,

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this is a rail at the top of the stairs, shooting in this direction, and shows Dr. Wilson’s body here, his feet extending into the bedroom.

Q    I believe this is the last photograph of Dr. Wilson.  If you will, relate to what the P-9 is, to the diagram, again.  What's depicted in this photograph?

A    Okay.  That's -- it's  Dr.  Wilson's  body, again, taken from an angle so you can  see  the  blood splattered  on  the  wall  there  at  the  door  jamb.

Q    Finally, this series of photographs, P-II, would you describe what that depicts or show the jury where this would be on the diagram.

A    There was a small desk  here  and  appeared they did  send  out  invitations, and a chair  sitting right  here,  and  Dr.  Wilson  was  directly  behind that. And you can also see the  clothing  bag  at  the top  of  the  stairway  on  --  near  the  landing  over there.

Q    So this item you are pointing to -- and, again, let's point so the jury can see the photograph, and we will pass it around.  But the item you are pointing to is the clothing bag you testified to earlier?

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A    Yes, sir.  That's in the stairway, and the landing is right there, and you turn and come upstairs, and then that's where the note was and the bat and Dr. Wilson’s body.

Q    Was that clothing bag clearly visible when it was photographed?

A    Yes, sir.

Q  You can have a seat.

(Brief  pause.)

Q    One last photograph, taken, I think, in that series upstairs.  Can you identify that?

A    it’s a battery charger and a telephone that's in Dr. Wilson’s bedroom.

Q    Was that in Dr. Wilson’s bedroom?

A    Yes, sir.

Q    It's not outside, it's actually inside? Show them where it is.

A    Dr. Wilson's bed was located right here between the two windows, and this is a small nightstand right there by that window, and it shows the phone and the battery charger there.

Q    Okay.  Was anything unusual, out of the ordinary, about the battery charger or –

A    The phone cord had been cut.

 

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MR.  HOOPER:   I  object to  "unusual"  or

"out of the ordinary."  He would have to qualify him as being –

MR. FRY:  Let me re-ask it.

Q    Did you notice anything about the appearance or the condition of the cord, the electrical cord to the answering machine or the charger?

A    The telephone wire had been cut.

Q    The telephone wire had been cut.  All right.

MR. FRY:  We offer this, if I didn't before. Your Honor, P-12.

THE COURT:  It’s already been offered.           MR. FRY:  All right.  Thank you.

Q    Glen,   as  a  part  of  your  crime  scene

investigation, did you prepare a video as a part of this case?

A    Yes, sir, we did.

Q    How did you do that?

A    We came back during the daylight hours

and Investigator Hutchinson and Investigator

Hamilton were taking still photographs of property in the house, and then I was taking the videotape of

 

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the house.

Q    All right.  Would you call that a walk-through of the house?

A    Yes, sir, it is.  Around the house and then through it.

Q    Around the house and then through it?

A    Yes, sir.

Q    Is it all of the house at 2700 Boulder Circle?

A    Yes, sir.

Q    Made of the back yard, too?

A    Parts of the back yard, yes, sir.

Q    At the time you took that video, had the house been secured?

A    It was still being secured by police officers on the scene 24 hours a day.

Q    24 hours a day? A    Yes.

Q   Did you use a video  camera  to  shoot  that? A    Yes,   sir.

Q    Does that video depict the flow of one room to another in that house?

A    Yes, sir, it does.

Q    Did you walk from one room to another as

 

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you took it?

 

A Yes,sir.

Q    I'm marking this as State's Exhibit No. 5.  See if you can identify that exhibit.

A    Yes, sir.  It's got my handwriting. Says, "2700 Boulder Circle."

Q   Does  that  appear  to  be  the  video  you shot?

A    Yes, sir, it is.

Q    Did you and I review that in my office a couple of weeks ago?

A    Yes, sir, last week.

MR. FRY:  Your Honor, we would like to offer into evidence the video.  We have got a television available.

MR. HOOPER:  Judge, we have seen the video and have no objection.

THE COURT:  Okay.  Then the exhibit is

admitted and may be viewed, but before we do that we will take a recess.

Ladies and gentlemen, you may go into the

jury room.

(Whereupon, proceedings were in recess at 2:25 p.m., until 2:45 p.m., at which time the

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following  occurred:)

THE COURT:  Mr. Fry, are you ready? MR. FRY:  We are. Your Honor. THE COURT:  You gentlemen ready? MR. DRAKE:  Yes.

MR. COOK:  Would Your Honor mind if I walked over and looked?

THE COURT:  Not at all.

MR. FRY:  Your Honor, I believe we have moved this exhibit in, I believe it’s been accepted.  We would ask -- and the defense has stipulated that Officer Nunley could give a description of what room is being viewed on the television.  We will ask him not to describe any evidence or make any editorial comments, but rather to describe what is being seen as far as rooms.

THE COURT:  He may do so. CONTINUATION OF DIRECT EXAMINATION

BY MR. FRY:

Q    Glen, you need to get where you can see and also where the court reporter can hear you and the jury can hear you.  Could you see back kind of on this side of this gentleman here?

A    Yes, sir.

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Q    Can you see okay from there?

A    Yes, sir.

Q    All right.  Now, this is the first time I have ever seen this thing.  Let’s see what happens here.

(Whereupon, the videotape, State's

Exhibit 5, was played to the Court and jury, and the following occurred:)

A    Okay.  This is shooting from Boulder Circle, shooting towards the front of the house, and it’s sort of panning down to the left side of the house, showing where the garage or driveway area is.

(Brief pause.)

A    Then backing off there and just showing the front of the house, again.  And this is just shooting off to the right to show the east side or the east lawn or east yard of the house.

(Brief pause.)

A    And this is just the east side of the house, and it shows the rock -- part of that rock garden and some flowers and stuff planted there.

(Brief  pause.)

A    Again,  the  east  side  of  the  house  and

 

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then panning back towards the back side of the house.  You will be able to see that deck, and the pool is right behind those trees there.

And this is the back of the house,

showing the deck and the back doors.  And that's the pool.

And that area there is the northwest part of the yard.  And that's the rock garden off to the left, again.

And that's the two-car garage and

shooting up, showing the west side of the house, and that's the front part of the house over there. And that's the pool area behind that white fence.

And this is walking into the front door of the house.

That shows the sitting room just inside the front door off to the left.

(Brief  pause.)

A    Still the sitting room.  And that area there, that doorway just past was the foyer area.

This is just inside the front door of the foyer there, that door there on the left is the sitting room, again.

That's the stairway there behind those

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plants, that go upstairs, there is a clock right there inside the front door, also.

(Brief pause.)

A    And that's the foyer that goes through the house and the stairway leading upstairs.  Shows around to the right, the dining room right there just inside the right side of the house.

(Brief pause.)

A    And that's the front door.

(Brief pause.)

A    And this is just the dining room.  We are still in the dining room, just shooting from a different direction.  And that's a doorway leading into the kitchen area.

This is walking into the kitchen right here.  That's the doorway leading back out to the dining room right there.  And that is all the cabinets and the refrigerator in the kitchen.  That doorway there leads back out into the foyer.  There is a door right there to the left that goes down into the basement.  And that's the door that goes out to the back.

You are walking out into that foyer now from the back side, behind the kitchen.  And that's

 

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shooting the foyer, again, from the back of the

house looking towards the front of the house.  And then back into the -- what's going to be the library there.  And the bar is located over there in that corner.

(Brief pause.)

A    That broken dish that was in the library is just now off to the left there.  And this is in the library, starting to look back out towards the

foyer.

(Brief pause.)

A    That's  the  bar,  again. That's  a  closer shot  of  the  bar  area.

(Brief  pause.)

A   That area right there  is  where  that  dish

was, the broken dish.

This is out in the foyer, again, I believe, walking southbound in the foyer.

There is a bathroom right there between the library and the sitting room.  The entrance is off the foyer.

(Brief pause.)

A   This is down in the basement, in  the  TV room or the large den area.  That  door  there  leads

 

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out into the back area where the swimming pool is.

(Brief pause.)

A     That's a desk there, that's in that TV

room or den area.  And that's a bathroom

downstairs.

(Brief pause.)

A     That's the hallway in the basement that

leads to the bedroom, the laundry room and the

closet, then off into the garage area.

That is looking into that bedroom

downstairs right there in front.

And this is the bedroom itself.

(Brief pause.)

A     And that's back out into the hall area of

the basement.

And that's a safe down in the bedroom.

That's a shotgun that's beside the bed in the

bedroom in the basement.   And that's a revolver

that was in the headboard of the basement --

headboard of the bed -- of the bed in the bedroom.

(Brief pause.)

A     That's a shot of the stairway that leads

from the basement back up toward the main floor of

the house.

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And that doorway there, it leads out to

the garage.

That's in the stairway going upstairs.

There is a laundry room downstairs, and

that's what we are looking through right there.

(Brief pause.)

A     And there is a closet right there, that's

in the basement, right before you get to the garage

area.

(Brief pause.)

A     That's another closet in the basement.

Now, this is the doorway that leads out

into the garage.

(Brief pause.)

A     That was the garage bay that's on the

front of the house, and that's shooting towards the

garage bay that's on the back side of the house.

(Brief pause.)

A     And that's the doorway leading from --

that was the doorway leading from the garage into

the house.

(Brief pause.)

Q     This is back up in the foyer, and these

are the stairs going up to the third floor of the

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house.

And that's the landing at the top of the stairway, that first landing, and it turns to the left and you go up to those other stairs to get to the third floor.

That's from the top of the stairway shooting down into the foyer. That's the front

door of the house there.

And the sitting room there.

The bathroom there.

And that's the top of the landing right

in this area right here. That's the area Dr. Wilson was laying at right there.

(Brief pause.)

A    That's the doorway there leading into

Betty Wilson's bedroom. And there is a closet back off to the left.

That's still upstairs in the foyer, though. That's the area there that Dr. Wilson was laying and the door leading into Betty Wilson's bedroom.

Again, that's another shot of the area where Dr. Wilson was laying and shooting into the doorway of Betty Wilson's bedroom.

 

Page 305

And that's that desk area where they sent out invitations or whatever.

And that is looking out towards the front of the house.  That's the doorway there that leads into the guest bedroom.

And that's the doorway that leads into

Dr. Wilson's bedroom.

This is walking into Dr. Wilson's

bedroom, there is a closet right there, his bed there, and there is two closets right there on the left side of the picture.

And that's a shot of the table area where that phone was that had the phone cord cut.

(Brief pause.)

A     That's just a shot of the two closets there inside Dr. Wilson's bedroom.

And that's a shot of the doorway going into Betty Wilson's bedroom.

(Brief pause.)

A    That's sort of like -- it's got a microwave  and sink area there in the bedroom.

(Brief pause.)

A    That is a locker or a gun case.

(Brief pause.)

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A   Now, this is from her bedroom shooting back into that bathroom area.

And then inside the bathroom.  There was another doorway that led to a large closet.  And this is a shot inside the closet.

(Brief pause.)

A   And that's a safe that was in the closet upstairs.

That's shooting back out into the bathroom from a closet.

And from the bathroom shooting back into

Betty Wilson's bedroom.

And that's the doorway leading out into

the foyer area where Dr. Wilson was found.

(Brief pause.)

A   And that's the doorway -- well, that's a closet out in the foyer.

(Brief pause.)

A   And that's the doorway leading into the

guest bedroom upstairs.

And that's from the bedroom shooting towards the door of the bedroom, and then the closet right there.

And this is a shot inside the closet.

Page 307

(Brief pause.)

A    And this is the doorway that leads to the bathroom between the guest bedroom and Dr. Wilson's bedroom.

And this is inside the bathroom.

(Brief pause.)

A    And we are back to Dr. Wilson's bedroom here.

And that's the end of the tape.

MR. FRY:  Judge, he is going to use it again, I think, on cross, unless you want to move it.

THE COURT:  Well, let's just leave it there, then.

Q    Glen

MR. FRY:  May I proceed, Your Honor?

Q    Glen, let me ask you a few questions about the video.  Throughout there it appears what looks like smudges on doors and door frames, like gun powder or some kind of black paint or

something.

A    Yes, sir, that's fingerprint powder.

Q    And where in the video is that visible?

A    It should be throughout the house.

 

Page 308

 

Q    Does it look like a smudge?

A    Just looks like dirt or ash or just a

 

dark area on the wall or whatever powder was on.

Q    Other than in the upstairs area where Dr. Wilson's body was found, was any human blood found in the house?

A    No, sir.

Q    Was any evidence of a struggle or an affray, that is, a fight, witnessed by you anywhere else in the house or anywhere in the house?

A    No, sir.

Q    You have already been through, with the jury, room by room, and now they have walked

through with the video. Did you make an investigation to determine if in fact the house had been burglarized, that is, had anything been taken?

MR. HOOPER:  Judge, I object, unless this man has been in the house before and knows the contents of the house.

THE COURT:  Sustained.

Q    Well, did you receive any reports of a burglary?

A    No, sir.

MR. HOOPER: Judge, I object again.

 

Page 309

THE COURT:  Mr. Hooper, the evidence is already in of such a report.   Overruled.

A     There was no report of a burglary, to my knowledge.

Q     Other than the call you got to go there?

A     Yes , sir .

THE COURT:  Well, let me withdraw that, then.  It was the call I referred to, not a report.

MR. HOOPER: Yes, sir.

THE COURT: Continue.

MR. FRY: Yes, sir.

Q     Did you observe any furniture broken or were there any drawers turned upside down that you saw going through the house, Officer Nunley?

A     No, sir, there were not.

Q     In any room?

A     No, sir.

Q     Were there things of value in the house?

A     Yes, sir.

Q     What do you remember being there?

A     There was silver, jewelry, fur coats, TV's, VCR's.

Q     When you say "silver," are you talking about the kind of jingling money we used to have or

Page 310

are you talking about the kind of silver that you make knives and forks out of?

A    Knives and forks, tea sets, silver

serving sets, whatever.

Q    Did you see that stuff?

A    Yes, sir.

Q    Where was it?

A    It was in the dining room, the silverware was.

Q    How did it appear?

A    Undisturbed.

Q    How many safes did you see in that house?

A    I saw two safes and some filing cabinets.

Q    Did you see any evidence of any attempted

entry into the safes?

A    No , sir .

Q    Were there any pry marks?

A    No, sir.

Q    Did the safes seem to be disturbed?

A    No, sir.

Q    I believe when you went through the

video, you said that there was a shotgun

downstairs; is that right?

A    Yes, sir, that was in Trey's bedroom, in

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the basement bedroom.

Q    Was there another weapon down there in Trey's bedroom?

A    Yes, sir, there was a revolver and a

knife that was in the headboard of the bed in the bedroom.

Q    All right. Where would the jury look for that if they decide to view this video later on? Where would they see the gun and the knife?

A    After we went through the TV room, then

we went into the bedroom downstairs in the

basement, it showed the bed that was unmade, a dresser, there was a couch in there, there was a set of golf clubs in there, looked like a boy's or young man's bedroom.

Q    Let me refer you now to, I believe, what you described as Dr. Wilson's bedroom.  Was there a heap of clothes on Dr. Wilson's bed?

A    When I shot the video, yes, sir.

Q    Do you know how those clothes got there?

A    I put them there, sir.

Q    And why were those clothes piled on the bed?

A    I took the clothes out of that first

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closet so I could fingerprint the inside of that closet wall and the inside of that closet door.

Q    Other than those clothes and other than,

I believe, a dish you referred to as being broken downstairs in one of those nice rooms downstairs, did you observe anything else out of the way or out of the ordinary about the house?

A    Well, the clothes --

MR. HOOPER:  Judge, I object, again, to

"out of the ordinary" unless this witness has ever been in the house and has knowledge.

MR. FRY: Let me ask it again, if I may. THE COURT: You may.

Q    Did you see any destroyed property or any evidence of recently broken furniture, to include drawers, desk, or any other kind of furniture?

A    No, sir, other than that broken dish in the library.

Q    Do you know who broke the dish in the library?

A    I don't know, sir.

Q    Now, did you recover some items from the house?

A    Yes, sir, I did.

Page 313

Q    Let me ask you to open this package, if you will.

(Brief pause.)

Q    Let me ask you to examine what I'm about to mark as State's Exhibit No. 61 Officer Nunley.

A    This is a bat that was upstairs on the floor of the foyer.

MR. FRY:  All right.  Is there any good place to stick this? On top.   Would counsel object to us covering up where it says, 113411 on top?

MR. DRAKE: Good place to put it.

MR. FRY:  Okay, State's Exhibit No. 6.

Q    And where did you find this bat, Officer Nunley?

A    That was upstairs in the foyer area,

about four or five feet north of where Dr. Wilson's body was.

Q    Is this the bat that was pictured in the photograph, a couple of them, that we showed to the jury earlier?

A    Yes, sir, it is.

Q    At the time you saw the bat, was its condition different in any way from the way you see it today?

Page 314

A      No, sir, not really.

Q      okay. What is this?   Do you know what

this is?  What this is?

A      This is blood up here and there is some

dirt, and I can't tell whether that's blood or dirt

there under the tape or not.

Q      Okay. At the time you saw the bat on the 22nd of May, did it have blood on it?

A      Yes, sir, it did.

Q      Appeared to be fresh?

A      Yes, sir.

Q      So that would be different then from today?

A      Yes, sir, it is dried.

MR. FRY:  We move this into evidence.

MR. DRAKE:  Which exhibit?

MR. FRY: No. 6.

MR. HOOPER:  We don't have any objection. THE COURT:  No. 6 is admitted.

MR. FRY:  Your Honor, I would offer it

for inspection, but I'm not going to put it on the rail.  It will fall off sure as the world.     It might wake some of us up if it did.

Q    Did you remove other articles from the

 

Page 315

scene that night that became a part of this investigation, Officer Nunley?

A   Yes, sir, I did.

Q   What other things did you remove, that

you recall?

A   The toboggan, there were -- telephone, glasses, several items.

Q   Let me show you this package and, again, ask you to go ahead and open it.   It seems to be sealed.

(Brief pause.)

MR. HOOPER: What exhibit is that?

MR. FRY: 7.

Q   What are you looking at there?

A   A ski mask, toboggan, face covering.

Q   Is it marked?

A   Yes, sir.

Q   Do you know who put that on there?

A   Mr. Kilbourne and Roger Morrison from the Department of Forensic Sciences.

Q   Have you seen that mask before?

A   Yes, sir.

Q   When did you see it?

A   On the night of the -- that I received [something missing]

Page 316

Q     Did you turn it over to the people at the forensic lab or somebody in your department?

A     I did, sir.

Q     You did yourself?

A     Yes, sir.

Q     You gave that to them?

A     Yes, sir.

Q     You have just received it back in a

sealed  container?

A     Yes, sir.

Q     With their initials on it, I believe; is that right?

A     Yes,   sir.

Q     It's your testimony you removed this State's Exhibit No. 7 from where in the house?

A     That was on Dr. Wilson's bed.

Q     On Dr. Wilson's bed.     Now, at the time

you were there, were all those clothes on his bed?

A     No, sir.   That was -- that and I believe some of the batteries or a screwdriver or something was on the bed.

Q     Okay.

MR. FRY:   Move this into evidence as State's Exhibit No. 7.

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State's Exhibit No. 7.

MR. HOOPER:  No objection.

THE COURT:  7 admitted.

Q     Let's go back through just a few photographs, Glen.

MR. FRY: Just a few more of these, Your Honor, and we will be through with this part of it.

I think these are easier to look at than the video sometimes.

Q     Let me let you look at State's Exhibit

No. P-40.  Can you identify that photograph, Glen?

A     That's a shot of the laundry room downstairs in the basement, shooting from the laundry room door, shooting into the laundry room.

Q     Is that depicted in the video, also?

A     Yes, sir, it is.

MR. FRY:  Move that into evidence,

State's Exhibit No. P-40.

THE COURT:  40 admitted.

MR. FRY:  You want to see these, Charlie? MR. HOOPER: Yeah.

(Brief pause.)

MR. HOOPER: Judge, we don't have objection to 41 through 49.

Page 318

Q    Let me let you authenticate these photos. Take a minute, if you will, and look at each one of them.  What I'll ask you after you have had a chance to look at each of them is, did you either make

these photos or were they made in your presence or do they depict what you saw as you worked the crime scene?

A    You want me to explain them?

Q    Look at all of them.

(Brief pause.)

A    Yes, sir, I made all those.

Q    All right.  Beginning with P-43, will you describe for the jury what this picture depicts?

A    A pair of shoes and a wallet that was found on the main floor of the residence, that's right at the entrance into the library.

Q    All right.  And to your recollection, is that visible in the distance in one of the other photographs you took down the hallway?

A    Yes, sir, I believe so.

Q    I show you what's been marked as State's Exhibit P-41.   I ask if you can describe the photograph in that exhibit.

A    This is a photograph of the north bay of

Page 319

  the garage.  There is a Mercedes, I believe, parked in that garage.  That's probably -- I didn't take that photograph, but I was there when it was taken.

Q     All right. Was the Mercedes still in the garage?  Is this the same car you took the video of ?

A     Yes , sir.

Q     Had it been moved, as far as you know?

A     No, sir, it had not.

Q     Do you know what model that is?

A     No, sir.

Q     This is Exhibit No. P-42.

A     That's a photograph of a note to Trey

from Greg or Gary, that was left on his dresser in the basement, in the bedroom in the basement.

Q     So this note was where in the basement?

A     On a dresser in Trey's bedroom.

Q     Okay.

A     That's in the basement.

Q     A note addressed to Trey?

A     Yes, sir.

Q     P-44.

A     This is a photograph from the laundry

room looking out into the hallway and the stairway that goes back to where the back of the kitchen and

Page 320

back of the foyer are located.

Q     P-45.

A     That's a desk, top area of the desk

that's in the basement in the TV room or the den area, whatever you want to call that room down there .

Q     Exhibit No. P-47.

A     That is Dr. Wilson's bed.       On the bed there was   a smoke detector and ski mask.

Q     You say the ski mask is on the bed?'

A     Yes, sir.

Q     Where is it located on the bed?

A     Right at the foot of the bed.

Q     Is this the only dark object at the rail at the foot of the bed?

A     Yes, sir.

Q     P-46.

A     This is the shot of -- it's in the bedroom in the basement, Trey's bedroom, and it shows the dresser, the two filing cabinets and the safe and a piece of the bed.

Q     Okay.   Was the filing cabinet drawer pulled out like that when you arrived, Glen?

A     Yes, sir.

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Q    So that was pulled out?

A    That was just ajar there.

Q    And what is that next to it, between the filing cabinet and the bed?

A    That's a safe there near the head of the bed, between the bed and the filing cabinets.

Q    Is this the bed you testified to earlier that there was a gun and a knife in the headboard?

A    Yes, sir.

Q    Which was it, the left or right-hand side of the bed; do you remember?

A    That's -- the pistol and the knife was up there on the right, the shotgun was at the left side of the bed.  That's not in that picture.

Q    Is there a door closed there?

A    Yes, sir, the headboard opens up.

Q    If you open-ed that headboard, what would you see?

A    A revolver and a hunting knife.

Q    What was on the other side of the bed?

A    On the other side of the bed, standing beside the bed, was a shotgun.

Q    Here is a picture I guess I should have shown you first.   P-49, what is that?

Page 322

 A    Front door of the house, looking into it.

Q    okay. Do you know whether or not the

door had been disturbed? Was it closed before this picture was made or is this the way it was on the night of Friday the 22nd?

A    When I got there that's how the door was. When officer Dunnagan and West got there, I don't know if it was open or closed.

Q    But this photograph was made on Friday night, May the 22nd?

A    Yes, sir.

Q    All right.  The night that you worked the crime scene?

A    Yes, sir.

Q    The first night?

A    Yes, sir.

Q    Now, after having worked the crime

scene -- I think you actually worked it a couple of times, didn't you?

A    Yes, sir, we worked it for about four or five days.

Q    Why so long?

A    We were trying to be very thorough.   We fingerprinted, I think, every room in the house.

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Then we went back with a search warrant and collected some other evidence.  And we just wanted to make sure we didn't miss anything.

Q    Were you able to obtain any fingerprints inside the house itself that were useful to you in your investigation?

A    We obtained several, what you call latent lifts or print cards, from the house, but none of them were identified to be -- to the killer in this incident.

Q    Was the ski mask that you identified earlier, which has been admitted -- was it

submitted to forensic sciences?   I believe you said it was; is that right?

A    Yes, sir, it was.

Q    What was the purpose of that?

A    To check to see if there were any hairs inside the ski mask and to find out who they

belonged to.

Q    Did they do that?

A    Yes, sir, they did.

Q    Did they make a report or did they make a discovery after having done that?

A    Yes, sir, they did.

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Q    Did they find a hair?

A    Yes, sir.

Q    Do you know whose it was?

A    It came back to James Dennison White.

Q    The co-defendant in this case?

A    Yes, sir.

Q    All right. Speaking of Mr. White, after having worked the crime scene for several days, did you at some point in time go down to Shelby County?

A    Yes, sir, I did.

Q    That was in the course of this investigation?

A    Yes, sir. we were running evidence to and from Montgomery to be analyzed and we stopped off in Shelby County.

Q    Why did you stop in Shelby County? What was your purpose there?

A    To search Mr. White's pickup truck.

Q    The truck that was identified to you as belonging  to James Dennison White?

A    Yes, sir.

Q    Did you search the truck?

A    Yes, sir, we did.

Q    Were some other folks with you?

Page 325

 

A     Investigator Hamilton was with me.

Q     Do you recall what all was removed from the truck?

A     Removed a library book, some other miscellaneous papers and things and a glove.

Q     Do you remember what day that was?

A     I can look it up.  I don't remember the exact date.

Q     Well, do you remember the murder was on a Friday?

A     Yes, sir.

Q     Was it the next week?

A     The next week, yes.

Q     I show you what I have marked as State's Exhibit No. 8.   1 ask if you can identify that this exhibit is.

A     It's a library book that we got from behind the seat of the pickup truck.

Q     You got it?

A     Yes, sir.

Q     You and some other officers?

A     Myself and Investigator Hamilton were there.  We  photographed it and collected it as evidence.

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Q     Made pictures of it, then you took it into evidence; is that right?

A     Yes, sir.

Q     What did you do with it?

A     We brought it back to Huntsville, photographed it, and then it was eventually turned back over to Carol Curlee in Montgomery to have it processed for fingerprints.

Q     Was Carol Curlee able to identify any fingerprints of any value to you in this investigation?

A     No, sir, she wasn't.

Q     You sure this is the book you got out of James White's car?

A     Yes, sir, out of his truck.

Q     Excuse me, his vehicle.

MR. FRY: Your Honor, we move State's Exhibit No. 8 into evidence.

THE COURT: Any objection?

MR. HOOPER: No objection.

MR. FRY: I need about two minutes, if I may, Your Honor.

(Brief pause.)

MR. FRY: Judge, that is all the

Page 327

questions I have of this witness.  Mr. Nunley, if

you can, answer whatever questions they have.

THE COURT:  Cross-examination.

CROSS-EXAMINATION

BY MR, HOOPER.:

Q     Officer Nunley, what time did you arrive on the scene?

A     I got there at two minutes after 10:00

p.m. on the 22nd.

Q     Sometime during the course of your stay, did you ask for the Department of Forensic Science

to assist your investigation?

A     I didn't personally request it.    It was Sgt. Colley that called them and had them cone out.

Q     Do you know John Kilbourne?

A     Yes, sir.

Q     Who is John Kilbourne?

A     He is a member of the Department of Forensic sciences that's in Huntsville.

Q     Does he have a similar job as you, to collect evidence?

A     Yes, sir.

Q     Okay.  And he came there -- out there on a Saturday,  I believe; is that correct?

Page 328

 

A    Yes, sir.

Q    Were you present?

A    I think I was called back to the scene

and he was  either there when I got there or he arrived moments later.

Q    Do you recall the -- I don't guess you were in here earlier, but do you recall a palm print being in the blood on the floor there by Dr. Wilson?

A    No, sir.

Q    You don't recall a palm print?

A    No, sir.

Q    So then you don't recall telling John Kilbourne   not to bother with examining that palm print, then; is that correct?

A    No, sir.

Q    Do you recall being advised by one of the uniformed   officers that there was a palm print in the blood   by this doctor?

A    No, sir.

Q    Officer, if you would, find the photograph that has the wallet in it.

MR. FRY:  It may be going around,

Charlie.

MR. HOOPER: Up here.    Okay.

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Q    I think you have identified that earlier. It's State's Exhibit 43; is that correct?

A    Yes , sir .

Q    All right.  You took that, I guess, on or about the  23rd day of May; is that correct?

A    Yes, sir.  Around midnight or so, I collected  it.

Q    Did you inventory that wallet at that time?

A    No, sir, I did not.

Q    In fact, tell the jury when it was inventoried, if it was.

A    I turned it in as is to the Department of Forensic science undisturbed.

Q    So you never looked in it?

A    No, sir.

Q    Never looked to see if it even had a dime in the wallet; right?

A    Well, we made a look with like hemostats, but we couldn't see anything.

Q    You didn't make any record of that, did you?

A    No, sir.

Q    Did you find -- do you recall Dr.

Page 330

 

Wilson's keys being found in the Mercedes?

A    I don't know whose keys they were.     I think there were some keys in it.

Q    And those keys were given to Trey Taylor; is that correct?

A    I don't know.

Q    Do you recall whether or not an

automobile was released to one of Mrs. Wilson's sons?

A    over those four or five days?

Q    Yes, sir.

A    Yes, sir, there was.

Q    Which automobile was it?

A    I believe it was the BMW.    I'm not sure.

Q    Well, was it not the first   automobile released was Dr. Wilson's?

A    I didn't release it, sir.

Q    You don't know?

A    No, sir.

Q    Did you examine the keys that were found in the Mercedes?

A    No, sir.

Q    Can you tell me why you wouldn't?

A    I didn't -- no, sir, I can't tell you, I

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Q    All right   You were there Saturday, the 24th -- excuse me, that would be the 23rd?

A    Yes, sir.

Q    Were you there when the police dogs were brought out?

A    I was called back there, I think the dog was there when I got there.

Q    Were you there when the dog was given the scent off this ski mask?

A    Yes, sir.

Q    And the dog trailed it, did he not?

A    As far as I know, the dog didn’t find any trail.

Q    The dog didn't track?

A    The dog was searching.   I don't know if

the dog found anything or not.

Q    Okay.  Tell me, if you recall, where the dog went from the house.

A    The back side of the house.

Q    It never left the area of the house?

A    Not while I was there, no, sir.            Q    You don't have any knowledge about the

dog trailing up to near Highway 431?

No, sir.

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A    No, sir.

Q    This shotgun downstairs that you found, officer, was it loaded?

A    I didn't check it, sir.

Q    How about the pistol?

A    I believe the pistol was loaded. I don't know why, but I think it was loaded.

Q    You didn't make any notes or anything

with respect to weapons being in the house and the condition of the weapons; is that correct?

A    Other than there were weapons there.

Q    But you didn't make any report with respect as to whether or not they were loaded?

A    No, sir.

Q    Or whether or not they had     or could be used?

A    No, sir, I didn't check them.

Q    Any particular reason you wouldn't check to see if the shotgun was loaded?

A    There wasn't anybody there that was going to use it.

Q    Well, you kept this house for how many days?

A    I believe it was five days. It may have

Page 333

been six.

Q     Wasn't it about two weeks, please, sir?

A     I don't recall it being two weeks.

Q     Okay.

A     After I finished my part, that was up to Investigator Brantley, and they  released it whenever they were through.

Q     The house was still in your custody or in your possession at the time Mr. White was arrested; is that correct?

A     I believe so, yes, sir.

Q     You knew the weapons were still in the house; is that correct?

A     Yes, sir.

Q     Didn't go back to ascertain the status of those weapons, that is, whether or not they were loaded or could have been used; is that correct?

A     No, sir.

Q     Do you recall any other weapons of any type that were in the house?

A     Other than kitchen knives?

Q     Right.

A     No, sir.

Q     Do you recall a machete being in the

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foyer upstairs?

A    No, sir.

(Brief pause.)

Q    Officer Nunley, let me go back to the wallet.  Is it your testimony that you didn't observe any money in the wallet?

A    I didn't see any money in it, no, sir.

Q    And you didn't make any report of that, did you? It wouldn't be found in any of your reports; is that correct?

A    No, sir.

Q    And you have testified earlier about whether or not there was anything of any value

taken from the house.   You said, "No," is that correct?

A    To my knowledge, no, sir.

Q    Well, did you just assume Dr. Wilson went around town broke?

A    No, sir.

Q    But you didn't find it worthy of making any report that there was no money found in his wallet?

A    After I released the wallet to the Department of Forensic Science.

Page 335

 

Q    Did you determine where Dr. Wilson

normally kept his wallet, were you advised?

A    No, sir.

Q    If you would, look at what's been marked

as Defendant's Exhibit 6.  1 will ask you if you

recall seeing that upstairs in the hallway, about

20 feet from where Dr. Wilson was laying.

A    That could have been, yes, sir.

Q    Okay.

A    That was up in the upstairs foyer.

Q    Yes, sir.  In fact, it was laying on top

of apiece of furniture there; is that correct?

A    A desk by that window.

Q    Yes, sir.

A    Yes, sir.

Q    Okay.  Now, this wasn't -- I don't

believe you took any photographs of this or

anything, did you?

A    No, sir.

Q    Okay.  Officer, did you attempt to fingerprint both the Mercedes and the BMW?

A    We attempted to fingerprint the Mercedes there on the scene. The BMW, by the time we got

down to the vehicles, I think had already been

Page 336

 

released.

Q   And you obtained -- got the BMW back at some point in time; is that correct?

A   I myself did not, sir.

Q   Well , do you recall it ever coming back into the possession of the police department?

A   Yes, sir, I do.

Q   In fact, Officer Nunley, were you advised by Mrs. Wilson or her son that they had noticed some damage  done to the rear trunk area by the rock?

A   No, sir.

Q   You don't recall that?

A   No, sir.

Q   Okay.  You don't recall the reason -- or. do you recall the police department being informed by Mrs. Wilson that you should look at the car

again, for some reason?

A   When the BMW was retrieved from Mrs. Wilson, it was turned over to the Department of Forensic Science, they were going to process that.

Q   Do you recall at some point in time Mrs. Wilson advising the police department that there

was some damage done or they noticed some damage to the rear of the car near the lock?

Page 337

 

A     I wasn't informed of that, no, sir.

Q     Did you do anything with respect to examining   the rear of the car to see if there was any damage?

A     No, sir, not of the BMW.

Q     Officer, I would ask you to look at what's  been marked as Defendant's Exhibit 2A, 2B, 2C, and 2D.  Are those photographs that were taken by the police department, appear to be?

A     Is that 2D?

Q     It's 2D.

A     Okay.

Q     A, B, C, D, and this would be E.

A     They could have been taken by me.   This was taken   after I did the closets - I don't know if I took that picture or somebody else took it.

Q     Okay.

A     Probably took those pictures.

Q     If you would, look at this photograph here, that's 2A, it has a ladder; is that correct?

A     Yes, sir.

Q     Did you try to make any determination as to why this ladder was sitting up in the den?

A     Dr. Wilson was reportedly trying to fix

Page 338

or change the battery in the smoke detector, I believe.

Q    And the smoke detector was found in the bed; is that correct? Dr. Wilson's bed?

A    The ladder was found down in the

basement,  and the smoke detector was found up on

his bed in his bedroom on the third floor.

(Brief pause.)

Q    Officer, I ask you to look at what's been marked as  Defendant's Exhibit 10 - that's not 10. Excuse me.  Exhibit 9, does that appear to be the same -- or appear to be a smoke alarm that you had found on the bed of Dr. Wilson?

A    It could be.

Q    okay. Similar in appearance; is that

correct?

A    Yes, sir.

Q    If you would, look at Defendant's Exhibit 10.   At some point in time did you recover a Diet Mountain Dew can from the -- Mrs. Wilson's black BMW?

A    I believe so, yes, sir.

Q    In fact, did you attempt to lift any fingerprints off of that can?

Page 339

 

A     It's been printed.  I don't recall

whether one had been lifted off of it or not.

Q     Do you recall that you received any results from Montgomery in which a fingerprint of Mrs. Wilson was lifted from a Diet Mountain Dew can that you turned in?

A     That would be Mrs. Curlee's -- it would

be in her report.  I don't recall offhand.

Q     Did you submit latent prints to Ms.

Curlee for identification?

A     Yes.

Q     Did you also submit prints taken from the house or other places to compare to known prints to Mrs. Curlee?

A     Yes, sir.

Q     And that was one of them, was it not?

A     I don't recall.  There were several.

Q     All right.  Do you have those records

with you?

A     No, Investigator Brantley or Mrs. Curlee will have them.

Q     Officer Nunley, Mr. Fry had asked you earlier about different photographs depicting the front door.  With respect to Dr. and Mrs. Wilson's

Page 340

 

house, was there any problem with opening that

front door once it was closed? What I am saying is: Did it stick?

A    It was a tight fit in the door, yes, sir.

Q    In fact, you had to pop the door to get it opened, did you not?

A    It took an extra amount of force to pop that door, yes, sir.  I don't know if you would pop it or whether you just force it hard.

Q    And the door would make a noise, would it not?

A    Yes, sir.

Q    The door in the garage that led from the garage into the house, it was in a similar shape,

was it not, which would stick and make a sound when you opened it?

A    Whether it made a sound, yes, I'm sure it would, but I didn't think that door had to be forced open or anything, no.

Q    Do you recall whether or not when you opened the door it would actually make a sound,

that is, where a door stuck?

A    I don't recall that.   I remember the.

front door being hard to open.   I don't recall the

Page 341

 

garage door being that hard to open.

Q    Officer Nunley, do you recall in the video and also some of your photographs that you took with respect to Dr. Wilson's bedroom, that there were two, I think, probably Queen Ann chairs, something of that nature, sitting on one side of

the room?

A    On the east wall, yes, sir.

Q    Yes, sir.  Do you recall whether or not there was some written material in one of those chairs?

A    There may have been.

Q    Do you recall whether or not you attempted to look through that material or inventory that material that was in the chair?

A    I myself didn't, no, sir.

Q    Do you recall seeing anything in that chair that was reflected as a note, a handwritten note, by Dr. Wilson?

A    No, sir.

Q    During the search of the house, did you find any items in the house that would identify Dr. Wilson through the military?

A    I believe there were some photographs of

Page 342

him in uniform by an airplane, but I don't remember any specific military type.

Q     Do you recall looking under his sink in his bathroom to find military ID's and things of that nature?

A     No, sir.

Q     You didn't look under there?

A     I don't recall seeing it under there, no, sir.

Q     Did you inventory those items under there?

A     No, sir.

Q     Do you recall in the guest bedroom

looking in the closet in there?

A     Yes, sir.

Q     All right.  Were there some items in there, children's items, costumes and hats, that kind of thing?

A     Some wigs.

Q     Yes, sir.

A     There was like a fake hand or something, costume-type.

Q     Do you recall seeing any military hats that were in there?

Page 343

 

A   There could have been.  I mean, I don't recall offhand, no, sir.

Q   All right.  So you don't remember looking for or seeing any notes written by Dr. Wilson that were laying in the chair in his bedroom?

A   I don't recall reading it or inventorying it.

Q   Any that were dated in time?

A   No, sir.

Q   Do you recall looking in his bathroom on his mirror to see -- do you recall any notes that were left stuck to his mirror?

A   There could have been, but --

Q   You didn't bother to read them?

A   I wasn't the only one there, sir.

Q   Well, I'm asking you.

A   No, sir, I didn't.

Q   Okay.  Officer Nunley, do you recall a blue pickup truck that belonged to Trey Taylor

being parked in the driveway?

A   Yes, sir.

Q   Do you recall me coming to you and advising you there was some damage done to the vehicle?

Page 344

 

A    Yes, sir.

Q    Apparently that hadn't been there, and would you do something as far as including that in your investigation?

A    Yes, sir.

Q    Did you do that?

A    Yes, sir.

Q    Do you recall me having to carry the

truck down to the Department of Forensic Science

for them to do it?

A    No, sir.

Q    You actually got the sampling?

A    Yes, sir.

Q    Okay.  Officer Nunley, one of the photographs that was introduced by Mr. Fry, No. 22, you may have to look at it.   Let me see if I can refresh your recollection.    It was actually a close-up of the railing in the rear of the yard.     Do you recall that photograph?

A    Yes, sir.

Q    And I think it actually had a hair in it; is that correct?

A    Yes.

Q    Anything significant about that?

Page 345

A    I was told to take a picture of it. I don't remember whether I took that picture or Investigator Hamilton took that picture.

Q    Was the reason to take the picture to include the hair and you recovered the hair?

A    I didn't collect it, no, sir.

Q    okay.  You didn't recover or collect the hair; is that correct?

A    I don't believe so, no, sir.

Q    I believe you have stated, also, you photographed the rear yard of the house; is that correct?

A    Parts of it, yes, sir.

Q    Okay. With respect to the -- I'm not sure which -- if it's east or west, it may be north or south, but the driveway, the apron at the

garage, which side of the house would that be on?

A    The driveway entered into the west side

of the house.

Q    West side.  All right.  Did you have an occasion to look of f the driveway to see -- to familiarize yourself with the contour of the land or the property right there on the side of the driveway?

Page 346

 

A    It appeared the land had been built up to level off for the pool, and there was a big slope from the pool going down.

Q    Are you familiar with the term, a "mink slide”?

A    No, sir.

Q    Well , that's going to be a very steep and slippery

A      grade.

Q      hill?

A    Yes, sir.

Q    Would that be a fair description of that? A    Yes, it was a steep grade.

Q    And the other side, where you have identified as a rock garden, is fairly flat; is

that right?

A    Or it led up, it sloped up.

Q    Do you recall on that side of the house that there  was stones placed that formed a path going to the rear of the property?

A    On the east side of the house?

Q    Yes, sir.

A    Yes, sir.

Q    There was a path; is that correct?

Page 347

A    Yes, sir.

Q    By placement of stones. officer, do you recall in the video that you took, with respect to Mrs. Wilson's bedroom, that portion that viewed the gun case?

A    Yes, sir.

Q    Do you recall that?

A    Yes, sir.

Q    That gun case was opened, was it not?

A    It was ajar, I don't think it was sitting open.

Q    It was open, was it not?

A    Yes, sir.

Q    Did you attempt to ascertain as to what type of gun had been kept in that gun case?

A    It was a pistol box, so I'm assuming a pistol was kept in it.

Q    Was there also not some ammunition in the box that would also reveal as to what type of gun it may have been in there with it?

A    Yes, sir, it was a revolver or --

Q    .38; is that right?

A    More than likely, yes, sir.

Q    Do you recall what type of ammunition was

Page 348

 

in the gun case?

A     I believe we collected it.  I'm not sure. (Brief pause.)

Q     Officer, I'll let you look at a photograph that's numbered 6A and B.  Can you refresh your recollection from that?

A     Yes, sir, that's .38 special ammunition that was in that gun -- pistol box, whatever you want to call it.

Q     Are you familiar with the term "wad' cutter'"

A     Yes, sir.

Q     What is a wad cutter?

A     It's a f lat-nose bullet, it has no rounded end or it's not hollow-pointed or anything like that.

Q     Generally used for target practice; is that correct?

A     Yes, sir.

Q     Leaves a nice crisp, round hole in the target?

A     Yes, sir.

Q     And it's a fairly cheap round; is that correct?

Page 349

 

A     Yes, sir.

Q     Did you at any time after this gun was recovered   from Mr. White, determine what type of ammunition was in the gun?

A     Yes, sir, I believe it's -- I don't

really recall.   I gave it to Micky Wednesday, I returned it to Micky.

Q     It was .38 wad cutters, was it not?

A     Yes, sir.

Q     Same type of ammunition that was f6und in this gun case?

A     Yes, sir.

Q     Glen, let me let you look at 6C and D or

A, B, C, and D, Defendant's Exhibit 6.     Does that fairly and accurately depict what the gun case

would look like?

A     Yes, sir.  I don't remember it being opened that much, because this definitely has been moved.

Q     Sure.  But that's what the gun case

looked  like; is that correct?

A     Yes, pistol box or gun case.

MR. HOOPER:  We would offer 6A, B, C, and D.

Page 350

MR. FRY:  Can I see it, Charlie?   I'm sure it's okay.

(Brief pause.)

MR. FRY:  No objection.

THE COURT:  I thought you said 6.   You

mean 2A?

MR. HOOPER:  6A, B, C, and D, four photographs under the number 6.

THE COURT: 6A?

MR. HOOPER:  6A as in apple, and B as in Bible.

THE COURT:  Talking about 6 as opposed to 2?

MR. HOOPER: Yes, sir.

THE COURT: 6?

MR. HOOPER: Yeah.

THE COURT: Okay.

Q     Micky, I believe you stated you processed the BMW; is that correct? Fingerprinted -- I'm calling you Micky and it's Glen?

A     Yes.  The BMW was still there in the garage.  Yes, sir, I think -- no, the-BMW was processed by Forensics, I believe.

Q     Were you there when they processed the

Page 351

car?

A    No, sir.

Q    Did you observe the car after it was processed?

A    No, sir.

Q    All right.   If you use -- you do fingerprinting, also; is that correct, or attempt

to find --

A    Yes, sir.

Q    Is it called latent prints?

A    Yes , sir.

Q    What kind of process do you have with respect to trying to find a latent print, that is, a print left by somebody on some object?

A    There are several different methods.     You can use plain powder, magnetic powder, you can

use --

Q    Let's stop with the powder.    Okay.

Whether it be magnetic powder or -- what did you

say?

A    Just plain black powder.

Q    All right.   The substance itself, it's

fairly dirty, I assume, is it not?

A    Yes, sir.

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Q    And if that was used on the car, it would  fairly well make it impractical to use, unless you wanted  to get it all over your clothes; is that not correct?

A    It would depend on who was doing the processing.

Q    Well, why, is somebody neater than others?

A    Yes, sir.

Q    If you are going to -- I assume if you have the car, if you are going to look for fingerprints, you are going to dust on the inside; is that correct?

A    Parts of it, yes, sir.

Q    Yes, sir.  And is there any reason --    any way that you necessarily would be able to keep it from getting on the seats or the steering wheel or anyplace else your hands would come in contact?

A    You wouldn't necessarily do the steering wheel because of the -- usually the texture of the steering wheel is going to be too rough to process, anyway.

Q    You say "usually." Does that mean you wouldn't even bother to see if you could lift a

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print off of it?

A     No, sir.

Q     Plastic is a good object, is it not, to retain a print?

A     The smooth parts.  A textured or pebbled surface, that the steering wheels are usually made out of, is not.

Q     Do you recall this steering wheel, what type it had?

A     I didn't process that one.

Q     You looked at the vehicle, did you not?

A     Yes, sir.

Q     Do you recall what it was?

A     No, sir.

Q     Well, if it was textured, that wouldn't prevent you from trying to make some determination or at least fingerprinting, would it not?

MR. FRY:  Your Honor, I object; he has testified that he didn't print it and he wasn't there when it was printed.   I don't see the relevance of asking him these questions.

THE COURT:  Mr. Hooper, he testified he didn't, he did not process the car.

MR. HOOPER:  Yes, sir.

Page 354

Q    Officer, do you recall the car being released back to the family?

A    Yes , sir.  I didn't release it, Investigator Brantley did.

Q    But you recall that?

A    Yes, sir.

Q    Certainly wouldn't be anything unusual to have it cleaned up, have the fingerprint dust removed from the car if , in fact, that was what was used to attempt to recover any fingerprints; is

that correct?

A    We don't usually clean  the things that we process, no, sir.

Q     You don't clean it up,  correct?

A     Right.

Q    So whoever you gave it  back to, they can either ride in it or clean it up; right?

A    Usually, yes, sir.

Q    Officer, how long have you been involved in crime scene work?

A    Eight years.

Q    I had asked you earlier about plastic

with respect to its being a good source for

retaining fingerprints; is that correct?

Page 355

A     Yes, sir, you did.

Q     Did you not tell me that a smooth surface would be a good object that would normally retain

or could retain a fingerprint?

A     It would depend on the method you are trying to use, also.

Q     Well, I'm talking about the object

itself , it would be conclusive to -- for a person to leave a fingerprint on it; is that correct?

A     Yes, sir.  If it's smooth, yes.

Q     Let's assume -- you have been to Kmart, have you not?

A     Yes, sir.

THE COURT:  Mr. Hooper.

MR. HOOPER: Yes, sir.

THE COURT:  Before we go to Kmart, let's take a recess.

MR. HOOPER: Judge, we just got a short visit.

THE COURT:  Ladies and gentlemen, we will take. a recess. Please go into the jury room.

(Whereupon, proceedings were in recess at 4:15 p.m., until 4:30 p.m., at which time the witness, Glen Nunley, resumed the stand, and the

Page 356

 

following occurred:)

THE COURT:   Mr. Hooper?

MR. HOOPER: Yes., sir.

THE COURT: You may now go to Kmart.

MR. HOOPER:   I was at Kmart, Judge.    I'm going to back up.   We are going to go to Wal-Mart first.

CONTINUATION OF CROSS-EXAMINATION

BY MR. HOOPE

Q    Officer Nunley, let me back up a little bit.  And for the benefit of the jury, would you explain the difference, if there is, between an ink print and a latent print.

A    An ink print is when a technician

actually rolls ink or puts ink on your hand and

rolls your hand across the paper to leave an impression.   A latent print is a print that's invisible until you apply powder to it. If a latent

print could be there, apply powder, then lift them from that surface.

Q    With respect to surface, some surfaces

are better than others for retaining a latent

print; is that correct?

A    Yes, sir.

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Q     And I think you have identified plastic

as being an excellent surface for containing a latent print?

A     I wouldn't say excellent. Depends on the condition of the plastic, whether it's got

scratches or old plastic, new plastic, and the method you use to try to raise the print off of the

plastic.                 

Q     But they are all certainly capable of holding a latent print; is that correct?

A     Theoretically, yes.

Q     Sure. Let's assume that you recover a latent print.  Is there any method to determine the length of time that that print has been on that object?

A     No, sir.

Q     It could be on there a day or five years, right?

A     Yes, sir.

Q     Do you recall sometime in July or August obtaining or finding a plastic bag that Mr. White identified as hiding in the woods near the Wilson home?

A     I didn't collect that. Investigator

Page 358

 

Hutchinson and Investigator Brantley recovered

that.

Q     Do you recall whether or not any fingerprints were recovered from the plastic bag?

A     Not by me, no, sir.

Q     Did you even attempt to fingerprint that plastic bag?

A     I didn't collect it.

Q     Do you know if anybody did?

A     Forensic -- it was turned in to Forensics for processing.  If you want to assume, I assume they did.

Q     All right. Can you tell me what items,

if any, the Huntsville Police Department attempted to determine whether or not latent prints were on those items that were identified as coming from or having been in contact with Mr. White?

A     There were several items in the house that were collected.  Several items collected, several items that the Department of Forensic Sciences collected, we fingerprinted several surfaces in the house, the walls, handrails, doors, door facings, glasses in the bar area, the telephones, all over the house.

Page 359

Q    Was there any property recovered from Mr. White that was fingerprinted?

A    The revolver.

Q    Well, any property?

A    Yes, sir, there was property recovered from White that was processed for prints.

Q    And what was that?

A    A revolver was recovered by Investigator Parker  or Investigator Payne.

Q    You mean they dusted the revolver for prints?

A    No, sir.   It was turned over to me and I processed it with Super Glue.

Q    Did you obtain anything?

A    Yes, sir.

Q    Were those -- was the report issued on that?

A    They -- those prints -- Super Glue is a different method.  It raises the print, and a white substance sort of cakes to the print., and about the only way you can lift the print off that surface is to photograph it.  So I photographed the print and then sent the print down to Mrs. Curlee.

Q    Okay.

Page 360

A   And whether she wrote a report, that

would be her --

Q   You never got a report back?

A   I didn't.

Q   Do you know if Officer Brantley got a

report back?

A   You will have to ask him.

Q   Do you know if a report was ever made available  to us, to the defendant?

A   I don't know.

Q   Okay.  With respect to Dr. Wilson's

bedroom, do you recall there being a night stand on each side of his bed?

A   Yes, sir, I would say there was one on

both   sides of the bed.

Q   Did you inventory the items that were in     J that   -- in either night stand?

A   No, sir.

Q   Did you even examine the items that were

in the night stand?

A   Other than to fingerprint the facings of

the night stand, no, sir.

MR. HOOPER:   No further questions.

THE COURT:   Any more questions, Mr. Fry?

Page 361

MR. FRY: No, Your Honor, no further questions.  Again, Your Honor, this officer is on duty in Huntsville.  We would ask he be excused

unless there is some reason that he would like to stay at the defense expense in Tuscaloosa.

THE COURT: Mr. Hooper, do you know of

any reason why you would need him further?

MR. HOOPER: I don't know why he would stay at my expense, Judge.  I don't know if we have got him subpoenaed.  If we do

THE COURT: Mr. Hooper, you didn't answer my question.

MR. HOOPER:   Yes, sir.

THE COURT: Do you know of any reason why Mr. Brantley can't be excused to go back to work?

MR. HOOPER:   I don't have any reason

right now, Judge.

THE COURT:   Then he may be excused.

Mr. Brantley, you may be excused.   Thank you.

MR. NUNLEY:   Nunley, sir.

THE COURT: Nunley. Mr. Brantley might want to be excused.

MR. FRY:   Your Honor, we call Dr. Embry,

Page 362


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