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          1                   UNITED STATES DISTRICT COURT
 
          2            FOR THE WESTERN DISTRICT OF NORTH CAROLINA
 
          3                        CHARLOTTE DIVISION
 
          4
               UNITED STATES OF AMERICA,    )
          5                                 )
                                            )
          6            vs.                  )  File No. 3:97CR23-P
                                            )
          7    AQUILIA MARCIVICCI BARNETTE, )
                                            )
          8            Defendant.           )
                                            )
          9
 
         10
 
         11                 Transcript of proceedings before the Honorable
 
         12    ROBERT D. POTTER, Senior United States District Court Judge,
 
         13    before Scott A. Huseby, Official Court Reporter and Notary
 
         14    Public, on the 22nd day of January, 1998.
 
         15    APPEARANCES:
 
         16    For the United States:
 
         17       ROBERT J. CONRAD, JR.
                  THOMAS G. WALKER
         18       Assistant United States Attorneys
                  227 West Trade Street, Suite 1700
         19       Charlotte, North Carolina  28204
 
         20    On Behalf of the Defendant:
 
         21       GEORGE V. LAUGHRUN, Esq.
                  Suite 602
         22       301 South McDowell Street
                  Charlotte, North Carolina  28204
         23
 
         24
 
         25
 
 
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          1    APPEARANCES: (Continued)
                  PAUL J. WILLIAMS, Esq.
          2       Suite 801
                  301 South McDowell Street
          3       Charlotte, North Carolina  28204
 
          4
 
          5                              ---
 
          6
 
          7            THE COURT:  Good morning, everyone.
 
          8            MR. CONRAD:  Good morning, Judge.
 
          9            MR. LAUGHRUN:  Good morning, Your Honor.
 
         10            THE COURT:  I understand Mr. Laughrun says that
 
         11    Mr. Conrad wants to put something on the record.  Is that right,
 
         12    Mr. Conrad?
 
         13            MR. CONRAD:  Not that I know of.
 
         14            MR. LAUGHRUN:  Well, Judge, yesterday afternoon we
 
         15    had --
 
         16            THE COURT:  Maybe you wanted him to put it on the
 
         17    record.
 
         18            MR. LAUGHRUN:  Well, no.  Yesterday afternoon, he and I
 
         19    talked about the Jencks request we made about 4:00 o'clock,
 
         20    4:15, whenever we recessed.  We talked about whether or not
 
         21    there would be any witnesses who had Jencks material.  He
 
         22    informed me and I take him at his word as I always have that
 
         23    there is no witness for the government going to testify that
 
         24    testified before the Grand Jury, and if that's the case our
 
         25    Jencks request is a moot issue, if Your Honor please.
 
 
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          1            MR. CONRAD:  That's what I told him.
 
          2            THE COURT:  Do you want the put on the record what you
 
          3    said?
 
          4            MR. CONRAD:  That's what I told him.
 
          5            THE COURT:  Okay, thank you.
 
          6            MR. LAUGHRUN:  Judge, also, there are some folks in the
 
          7    courtroom, we don't know if they're witnesses or not, and I --
 
          8    other than the victim impact witnesses, Your Honor already has
 
          9    ruled on over our objection.
 
         10            THE COURT:  Any witnesses back there?  Shouldn't be.
 
         11            (No response.)
 
         12            MR. LAUGHRUN:  I mean, we just don't know who they are
 
         13    and we would just make that request.
 
         14            THE COURT:  Thank you, sir.  Call the jury.
 
         15            (The jury returned to the courtroom.)
 
         16            THE COURT:  Good morning, ladies and gentlemen, hope you
 
         17    had a pleasant evening.  I'm going to have to ask you each
 
         18    morning whether or not any of you have seen, heard or read
 
         19    anything about this case.
 
         20            (No response.)
 
         21            THE COURT:  Anybody discuss it with you?
 
         22            (Jurors shake heads.)
 
         23            THE COURT:  All right, thank you very much.  I
 
         24    understand from the shaking of the heads that nobody has seen,
 
         25    heard or read anything about it, nor has anyone discussed it
 
 
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          1    with you, is that correct?
 
          2            (Jurors nod heads.)
 
          3            THE COURT:  Thank you very much.  Call your next
 
          4    witness.
 
          5            MR. CONRAD:  The United States would call Melinda
 
          6    Burden.
 
          7            MR. WILLIAMS:  What is the name of the witness?
 
          8            MR. CONRAD:  Burden.
 
          9                             MELINDA BURDEN,
 
         10    being first duly sworn, was examined and testified as follows:
 
         11                           DIRECT EXAMINATION
 
         12            BY MR. CONRAD:
 
         13       Q.   Would you please state your name for the jury?
 
         14       A.   Melinda Burden.
 
         15       Q.   Ms. Burden, how old are you?
 
         16       A.   17.
 
         17       Q.   In April of '96, how old were you?
 
         18       A.   16.
 
         19       Q.   Where do you live?
 
         20       A.   Roanoke.
 
         21       Q.   Now, in April of 1996, what was your street address?
 
         22       A.   I can't remember.
 
         23       Q.   Okay.  Let me approach and hand to you what's been
 
         24    introduced into evidence as Government's Exhibits 7F, G, H and
 
         25    I, and ask if you recognize this area of Roanoke?
 
 
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          1       A.   Yes, I do.
 
          2       Q.   Okay, and what do you recognize it as?
 
          3       A.   That was my house (indicating) right there.
 
          4       Q.   All right.  And do you know Robin Williams?
 
          5       A.   Oh, no, I didn't know her personally.
 
          6       Q.   Did you know where she lived?
 
          7       A.   Uh-huh, right here.
 
          8       Q.   Okay.  So your house is right here (indicating)?
 
          9       A.   Uh-huh.
 
         10       Q.   And Robin Williams' house is on the corner that you just
 
         11    pointed out?
 
         12       A.   Uh-huh.
 
         13       Q.   Is there -- does your house include this property in
 
         14    here (indicating)?
 
         15       A.   All the way to back here it does (indicating).
 
         16       Q.   And is there a path that goes through that area?
 
         17       A.   Yes, there is a way you can come over here in the yard
 
         18    and look all the way down and see everything down here.
 
         19       Q.   If you go down that path, can you see Robin Williams'
 
         20    apartment from your property?
 
         21       A.   Uh-huh.
 
         22       Q.   In April of 1996, did anything unusual happen?
 
         23       A.   Yes.
 
         24       Q.   In the wee hours of the morning?
 
         25       A.   Uh-huh.
 
 
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          1       Q.   Go ahead and tell the jury what happened.
 
          2       A.   I was sleeping and I heard, I think it was four
 
          3    gunshots.
 
          4       Q.   Uh-huh?
 
          5       A.   And I woke up and I went outside, and I heard this woman
 
          6    screaming and banging on the people's doors screaming, help me,
 
          7    help me, he is going to kill me.  And I heard glass breaking,
 
          8    and I seen a car come up my road with loud music on, and the
 
          9    person that was in it went down a dead end street, came back
 
         10    right by my house, by me and my mother.  And he had his arm up,
 
         11    looked like he was adjusting the rear view mirror, and I seen
 
         12    the fire of a cigarette in the passenger seat, and that's really
 
         13    all I seen.
 
         14            MR. CONRAD:  That's all I have, Judge.
 
         15            THE COURT:  Cross?
 
         16                            CROSS-EXAMINATION
 
         17            BY MR. LAUGHRUN:
 
         18       Q.   Ms. Burden, did you give a statement to the police,
 
         19    ma'am?
 
         20       A.   My mother did.
 
         21       Q.   No, did you give one, ma'am?
 
         22       A.   No, sir.
 
         23       Q.   Give a statement to any FBI agents?
 
         24       A.   Yes.
 
         25       Q.   Who did you talk to, ma'am?
 
 
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          1       A.   I think it was Mr. Conrad.
 
          2       Q.   Mr. Conrad being the prosecutor here?
 
          3       A.   Yes.
 
          4       Q.   Did you talk to anybody besides Mr. Conrad or Mr. Walker
 
          5    seated at that table?
 
          6       A.   Yeah, I talked to a man that came to my house.
 
          7       Q.   Did he write down what you said?
 
          8       A.   No.
 
          9       Q.   Did he record it on tape or any way at all?
 
         10       A.   No.
 
         11       Q.   Is that someone from the Roanoke police department?
 
         12       A.   Yes, I think.
 
         13       Q.   Now, you folks had some dogs on your property, did you
 
         14    not?
 
         15       A.   Right.
 
         16       Q.   When you lived there?
 
         17       A.   Yes, we had one.
 
         18       Q.   And did it sleep outside?
 
         19       A.   Yes.
 
         20       Q.   Was it barking that night?
 
         21       A.   I'm not sure.
 
         22       Q.   And you can't identify anybody in the car, can you?
 
         23       A.   No.
 
         24       Q.   Can you give us a description of the car?
 
         25       A.   It was like a little sports car.  It had primer spots on
 
 
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          1    it.
 
          2       Q.   Okay.  Have you ever been shown a picture of that car at
 
          3    all?
 
          4       A.   No.
 
          5            MR. LAUGHRUN:  Thank you, ma'am.  Thank you, Judge
 
          6    Potter.
 
          7            THE COURT:  Redirect?
 
          8            MR. CONRAD:  No, sir.
 
          9            THE COURT:  Thank you, ma'am, appreciating you coming,
 
         10    thank you.  Call your next witness.
 
         11            MR. CONRAD:  The United States would call Maude
 
         12    Hubbard.
 
         13                            MAUDE G. HUBBARD,
 
         14    being first duly sworn, was examined and testified as follows:
 
         15                           DIRECT EXAMINATION
 
         16            BY MR. CONRAD:
 
         17       Q.   Ms. Hubbard, can you state your name for the jury?
 
         18       A.   My name is Maude G. Hubbard, and the G is for Gail.
 
         19       Q.   Do they also call you Granny?
 
         20       A.   Right, right.
 
         21       Q.   Where do you live, Ms. Hubbard?
 
         22       A.   I live at 1618 Keswick Avenue, Northeast, that's -- I
 
         23    moved downstairs.  I were staying at 1614.  They moved me down
 
         24    up underneath there.
 
         25       Q.   And that's in Roanoke?
 
 
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          1       A.   Right, Roanoke, Virginia.
 
          2       Q.   And 1614, would that be the apartment next to --
 
          3       A.   Next to where Robin, yes, sir.
 
          4       Q.   Next to 1616?
 
          5       A.   Right, right.
 
          6       Q.   And in April of last year, or I'm sorry, April of 1996,
 
          7    were you living in 1614, next door to --
 
          8       A.   Yes, I were.
 
          9       Q.   And then sometime after that, you moved down behind in
 
         10    the back of the apartment?
 
         11       A.   Right, right.
 
         12       Q.   Okay.  Do you know Bertha Williams?
 
         13       A.   Yes, I do.
 
         14       Q.   How do you know Ms. Williams?
 
         15       A.   We all go to church, we are in the same church together,
 
         16    and I been knowing her for a number of years.  We worked
 
         17    together.
 
         18       Q.   Do you see her in the courtroom today?
 
         19       A.   Bertha Williams?
 
         20       Q.   Yes, ma'am.
 
         21       A.   Yes, I do.
 
         22       Q.   Do you know Robin Williams?
 
         23       A.   Yes, I do.
 
         24       Q.   How do you know Robin?
 
         25       A.   I knew her from a young girl when she was in school.  I
 
 
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          1    been knowing her practically all of my life.
 
          2       Q.   And at some time, did Robin move next door to you?
 
          3       A.   Yes, she did.
 
          4       Q.   Okay.  And at some time, did a boyfriend ever move in
 
          5    with her?
 
          6       A.   Yes.
 
          7       Q.   Do you remember the events of the night of the fire
 
          8    bombing?
 
          9       A.   Yes, I do, but I had gone to sleep.  See, I'm a
 
         10    diabetic, and I had went to sleep, and they came there and woke
 
         11    me up and said, Granny, get up, get up, get up.
 
         12       Q.   And who did that?
 
         13       A.   That was Doris Coleman, the lady up the hill from me.
 
         14       Q.   And after Doris Coleman -- how did she wake you up?
 
         15       A.   She just kept hollering, Granny, Granny, Granny, Granny
 
         16    and knocking at the door.  And Mr. Grub stayed down up under me,
 
         17    I'm staying in his apartment now, and he came up there and his
 
         18    little boy and said, Come on, get on out, Granny, get on out.
 
         19    And I seen all of this out there, I just didn't know what was
 
         20    going on.
 
         21       Q.   Okay.  And after Ms. Coleman and Mr. Grub got you up,
 
         22    what happened after that?
 
         23       A.   Well, I just like everybody else, I put my coat and
 
         24    stood there and seen the fire trucks and everything.  And at
 
         25    that time, Ms. Coleman come down, well, see, Robin, I heard
 
 
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          1    someone hollering.  But you know when you are in the apartment
 
          2    at my age, you know, I didn't catch her voice until she went up
 
          3    and then she came back, and then she was hollering Granny,
 
          4    Granny, help me, help me, Granny, this didn't have to happen to
 
          5    me.  And they brought her in there and they had this cloth on
 
          6    her arm, and she went to pull on it and all the flesh and
 
          7    everything fell.  I said, oh, my God.  She said, call my mama,
 
          8    when I tried to -- I didn't have a phone, my wires had been cut.
 
          9       Q.   So as best as you can remember, what did Robin tell you
 
         10    when she came with the towel around her arm, what did she say to
 
         11    you?
 
         12       A.   She just said, Granny, look here, look, Granny, said, he
 
         13    tried to kill me, tried to kill me, said, Granny, I don't
 
         14    deserve this, Granny, I don't deserve this.  And I told her, she
 
         15    said, call my mama.  But I went there to try to call her, but
 
         16    there was no phone, the phone was dead.
 
         17       Q.   Did you pick up your phone?
 
         18       A.   Yeah, I picked it up and it was dead, and I said,
 
         19    Robin --
 
         20       Q.   There was no dial tone?
 
         21       A.   No dial tone whatsoever.
 
         22       Q.   Did you later learn what happened to your phone?
 
         23       A.   Yes.
 
         24       Q.   Tell the jury about that.
 
         25       A.   I learned that Mark had cut my line and hers.
 
 
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          1       Q.   And how did you learn that?
 
          2       A.   Huh?
 
          3       Q.   How did you learn that?
 
          4       A.   Well, that's what Mr. Grub said, it's the only way,
 
          5    because everybody else had telephone service but me and Robin.
 
          6       Q.   Did he show you anything, Mr. Grub, did Mr. Grub show
 
          7    you anything the next day?
 
          8       A.   Yeah, next day he went out there and just, you know, put
 
          9    it back for me.
 
         10       Q.   Did you see the phone lines?
 
         11       A.   Yeah, it was -- before he cut it, he showed me, uh-huh.
 
         12       Q.   All right.  Now, with Robin living next door to you, did
 
         13    you -- did you have occasion to see her coming and going?
 
         14       A.   Yeah, I seen her coming and going to work.
 
         15       Q.   Did you ever see her boyfriend Mark Barnette come?
 
         16       A.   Yes, all the time, because he drove the car most of the
 
         17    time.  He'd take her to work and go pick her up from work.
 
         18       Q.   And you would see Mr. Barnette doing that?
 
         19       A.   Yeah, I seen him, uh-huh.
 
         20       Q.   Would Robin drive the car or would Mr. Barnette?
 
         21       A.   Mr. Barnette.  He did most of the driving.
 
         22       Q.   And whose car was it?
 
         23       A.   It was Robin's.
 
         24       Q.   Okay.  Now, you had indicated that your -- you are a
 
         25    family friend, is that accurate, you're a friend of the Williams
 
 
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          1    family?
 
          2       A.   Right, right.
 
          3       Q.   Long time?
 
          4       A.   Long time.
 
          5       Q.   After Robin moved in next door to you, did she ever come
 
          6    over and talk with you?
 
          7       A.   Me and her, we just had a little, small stoop.  We'd sit
 
          8    there and talk.  She confirmed different things with me, because
 
          9    she'd always, you know, asking for advice and I -- you know, I
 
         10    have children and I know, and I always talked to her, give her
 
         11    as a mother and a grandmother.
 
         12       Q.   Did she ever talk to you about her relationship with
 
         13    Mr. Barnette?
 
         14       A.   Yes, she did.
 
         15       Q.   And what would she tell you?
 
         16            MR. LAUGHRUN:  Objection, Judge.
 
         17            THE WITNESS:  She just said he done got to be so
 
         18    possessive.
 
         19            MR. CONRAD:  Granny, hang on a second.
 
         20            THE COURT:  Wait just a minute, there's an objection.
 
         21    You're objecting to this on what grounds?
 
         22            MR. LAUGHRUN:  Hearsay, Your Honor.
 
         23            THE COURT:  Overruled.
 
         24            BY MR. CONRAD:
 
         25       Q.   Go ahead, Granny, what did Robin tell you about her
 
 
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          1    relationship with the defendant?
 
          2       A.   She said she couldn't get rid of him, she just didn't
 
          3    want to be bothered with him, she wanted him out of there, he
 
          4    was too possessive.
 
          5       Q.   Did she tell you why she wanted to get rid of him?
 
          6       A.   Because he was fighting her and --
 
          7       Q.   Were there ever any incidents before the fire bombing?
 
          8       A.   Yes, it was, yes, it was.
 
          9       Q.   And would you hear that?
 
         10       A.   Did I hear it?  No, she came back out of the house from
 
         11    her apartment over there to tell me -- to call her mother one
 
         12    night.  He had jumped on her.
 
         13       Q.   And how long before the fire bombing did that occur?
 
         14       A.   It wasn't too long, really I just couldn't exactly tell
 
         15    you the date and all that.
 
         16       Q.   On that night when she came over and said he had jumped
 
         17    on her, what was her attitude like?
 
         18       A.   Nothing, she just said, I want my mama, I want my mama,
 
         19    I'm going to call my mama.  And it wasn't but a few minutes
 
         20    before sister Bertha was there.
 
         21       Q.   So you did call Ms. Williams at least on one occasion to
 
         22    tell her about the fire bombing?
 
         23       A.   Yes, I called her, yeah, I called her.
 
         24       Q.   And then she came over?
 
         25       A.   Yes.
 
 
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          1            MR. CONRAD:  That's all I have, Your Honor.
 
          2            THE COURT:  Cross?
 
          3                            CROSS-EXAMINATION
 
          4            BY MR. WILLIAMS:
 
          5       Q.   When you first, Ms. Hubbard, knew that Robin and Mark
 
          6    were dating, at the beginning of that relationship, she was very
 
          7    happy and in love with Mark, wasn't she?
 
          8       A.   Seemed like it to me, she did.
 
          9            MR. WILLIAMS:  Thank you.
 
         10            THE COURT:  Redirect?
 
         11            MR. CONRAD:  No, sir.
 
         12            THE COURT:  Thank you, ma'am, you may step down,
 
         13    appreciating you coming.  Call your next witness.
 
         14            MR. CONRAD:  The United States would call Ray Williams.
 
         15                              RAY WILLIAMS,
 
         16    being first duly sworn, was examined and testified as follows:
 
         17                           DIRECT EXAMINATION
 
         18            BY MR. CONRAD:
 
         19       Q.   Sir, would you state your name for the jury?
 
         20       A.   Ray Williams.
 
         21       Q.   Mr. Williams, are you related to Bertha Williams?
 
         22       A.   Brother, yes, sir.
 
         23       Q.   She is your sister?
 
         24       A.   Yes, sir.
 
         25       Q.   Do you see Bertha in the courtroom today?
 
 
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          1       A.   Today?
 
          2       Q.   Yes.
 
          3       A.   Yes, I see her back there.
 
          4       Q.   So, Robin Williams would be your niece?
 
          5       A.   That's right.
 
          6       Q.   Do you remember an incident -- I'm sorry, Mr. Williams,
 
          7    where do you live?
 
          8       A.   I live at 703 Hunt Avenue, Roanoke, apartment 27.
 
          9       Q.   And back in April of 1996, where did you live?
 
         10       A.   911 Loudon.
 
         11       Q.   And is that your sister Bertha's house at 911 Loudon
 
         12    Avenue in Roanoke?
 
         13       A.   Yes, sir.
 
         14       Q.   Do you remember a time in April when -- did you know
 
         15    where Robin lived back then?
 
         16       A.   Yes, I did.
 
         17       Q.   Did you recall a time when her apartment was fire
 
         18    bombed?
 
         19       A.   Yes, sir.
 
         20       Q.   Where did Robin go after her apartment was fire bombed?
 
         21       A.   She went to the hospital.
 
         22       Q.   And how long was she at the hospital, best you can
 
         23    remember?
 
         24       A.   I don't remember all that, but she was in there quite a
 
         25    while.
 
 
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          1       Q.   Okay.  And during the time that she was at the hospital,
 
          2    do you know if that hospital was in Charlottesville, Virginia?
 
          3       A.   Charlottesville.
 
          4       Q.   And was your sister Bertha in Charlottesville at that
 
          5    time with Robin?
 
          6       A.   Yes, sir, all the time.
 
          7       Q.   And were you living -- strike that.
 
          8            Was your nephew Kenneth with his mother in
 
          9    Charlottesville?
 
         10       A.   Yes, he was.
 
         11       Q.   So were you living by yourself at 911 Loudon during that
 
         12    time?
 
         13       A.   At that time, yes.
 
         14       Q.   And during that time when Robin was at the hospital in
 
         15    Charlottesville, did you receive a phone call?
 
         16       A.   I sure did.
 
         17       Q.   All right, and go ahead and tell the jury about that
 
         18    phone call.
 
         19       A.   Well, the -- the fellow called and wanted to say he was
 
         20    concerned about Robin, wanted to know how she was.
 
         21            MR. LAUGHRUN:  Objection to hearsay.
 
         22            THE COURT:  Wait a minute.  Objection overruled, go
 
         23    ahead.
 
         24            THE WITNESS:  And wanted to know where she was at, and I
 
         25    told him, you know where she is at.
 
 
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          1            BY MR. CONRAD:
 
          2       Q.   Let me stop you right there Mr. Williams and ask you a
 
          3    couple of questions.  When the fellow called and asked about
 
          4    Robin, did you recognize the voice?
 
          5       A.   I sure did.
 
          6       Q.   How did you recognize the voice?
 
          7       A.   Well, I knew who he was, because I been seeing him the
 
          8    whole time he was with Robin.
 
          9       Q.   And whose voice was it that you heard on the phone?
 
         10       A.   Well, it was Mark.
 
         11       Q.   Do you see the person you've called Mark in the
 
         12    courtroom today?
 
         13       A.   Yes, right there.
 
         14       Q.   Would you point him out to the jury and tell the jury
 
         15    what he is wearing?
 
         16       A.   There he is right there.
 
         17       Q.   At the table next to me?
 
         18       A.   Next to you.
 
         19       Q.   Sitting in the middle between two gentlemen?
 
         20       A.   Yes, sir.
 
         21       Q.   Now, prior to getting that phone call, how many times
 
         22    had you seen or heard Mark's voice?
 
         23       A.   Oh, every time he come up to the house or come around,
 
         24    you know, I knew who it was.
 
         25       Q.   Is there any doubt in your mind that's who you talked to
 
 
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          1    on that phone?
 
          2       A.   No, sir.
 
          3       Q.   Okay.  Now, as best you remember, tell the jury exactly
 
          4    how the conversation went.
 
          5       A.   From what I remember, he called and asked me how was
 
          6    Robin.
 
          7       Q.   And what did you say?
 
          8       A.   I just remember, but he said, what did he say, he was
 
          9    concerned about Robin, where was she at, and I told him, you
 
         10    know where she is at, just like that.  And we just had a few
 
         11    more words or something like that, you know.
 
         12       Q.   Did you ask him why he did it?
 
         13       A.   I sure did.  I said, Mark, why would you do something to
 
         14    Robin like that, and he told me, sir, Ray, I didn't do it but I
 
         15    know who done it, just like that.  And I told him he is a
 
         16    goddamn liar, just to use my expression, and hung up in his
 
         17    face.
 
         18       Q.   And after you hung up with him, what did you do?
 
         19       A.   I just remember I think I called somebody, I don't know
 
         20    who I called.
 
         21       Q.   Do you remember calling Kenny?
 
         22       A.   I talked to Kenny on the phone.
 
         23       Q.   After you hung up, did you make any attempt to figure
 
         24    out what number he had called you from?
 
         25       A.   Well, he told me, Kenny told me to --
 
 
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          1            MR. LAUGHRUN:  Objection.
 
          2            THE WITNESS:  -- look on the --
 
          3            MR. LAUGHRUN:  Objection.
 
          4            THE COURT:  Overruled.
 
          5            MR. CONRAD:  Go ahead, Ray.
 
          6            THE WITNESS:  To look on the box and get the number, but
 
          7    I really don't remember too much about that.
 
          8            BY MR. CONRAD:
 
          9       Q.   Well, did you -- let me ask you this:  Did you look on
 
         10    the box and get the number?
 
         11       A.   Yeah, I did, I did.  I wrote the number down.
 
         12       Q.   You wrote the number down.  Did you ever tell Kenny the
 
         13    number?
 
         14       A.   Yes, I did.
 
         15            MR. CONRAD:  That's all I have.
 
         16            THE COURT:  Cross?
 
         17            BY MR. WILLIAMS:
 
         18       Q.   Mr. Williams, just very briefly.  When you first met
 
         19    Mark and knew that they were -- he had met and began a
 
         20    relationship, at the beginning of that relationship you knew
 
         21    that Robin and he were very much in love?
 
         22       A.   I don't know nothing about all that being very much in
 
         23    love, it was just a little old fling, you know, that's all I
 
         24    thought it was, a little old fling.
 
         25       Q.   When Mark moved into the apartment with Robin, didn't
 
 
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          1    you help Mark move in?
 
          2       A.   Did I help?  I was there.  I didn't help, I couldn't do
 
          3    nothing.
 
          4            MR. WILLIAMS:  Thank you, sir.
 
          5            THE COURT:  No redirect, thank you very much.
 
          6            THE WITNESS:  Yes, sir.
 
          7            THE COURT:  Call your next witness.
 
          8            MR. CONRAD:  The United States would call Kenneth
 
          9    Williams.
 
         10                            KENNETH WILLIAMS,
 
         11    being first duly sworn, was examined and testified as follows:
 
         12                           DIRECT EXAMINATION
 
         13            BY MR. CONRAD:
 
         14       Q.   Would you tell the jury your name, please?
 
         15       A.   Kenneth Williams.
 
         16       Q.   Kenneth, you are going to have to pull that microphone
 
         17    closer to you.
 
         18       A.   Kenneth Williams.
 
         19       Q.   And Kenneth, do you live in Roanoke, Virginia?
 
         20       A.   Yes, sir, that's correct.
 
         21       Q.   Are you related to Bertha Williams?
 
         22       A.   Yes, sir.
 
         23       Q.   How?
 
         24       A.   That's my mother.
 
         25       Q.   And so Robin Williams would be your sister?
 
 
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          1       A.   Yes, sir.
 
          2       Q.   Now, you've been in the courtroom during this testimony,
 
          3    have you not?
 
          4       A.   Yes, sir.
 
          5       Q.   Did you hear your Uncle Ray just testify?
 
          6       A.   Yes, sir.
 
          7       Q.   Did there come a time when you talked to him from
 
          8    Charlottesville, Virginia?
 
          9       A.   Yes, sir.
 
         10       Q.   And what did you talk about?
 
         11       A.   Well, I was down there and I called up there because he
 
         12    was staying at my mother's house to see if he was all right.
 
         13    And we talked, and then he told me that Mark had called there
 
         14    and he told me what he had said, where she was at.  And then
 
         15    I -- and then I hung up, and then I went back in the room
 
         16    because I called from a pay phone.  And I told my mother to come
 
         17    outside or something, out of the room because I didn't want my
 
         18    sister to hear, and I told her that Uncle Ray said that he had
 
         19    called.  And she said, Kenny, call him back and tell them to
 
         20    push the I.D. and get the number, so I did.  Then afterwards --
 
         21       Q.   Just take your time, Kenny.
 
         22       A.   Huh?
 
         23       Q.   Just take your time.
 
         24       A.   Okay.  And then afterwards, I called the operator to see
 
         25    what area code, what city, and she told me it was North
 
 
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          1    Carolina, so I said okay.  So the next day --
 
          2       Q.   Did there come a time -- did your Uncle Ray give
 
          3    you -- did he -- do you know whether or not he pushed the I.D.
 
          4    button to get that number?
 
          5       A.   Well, I didn't actually see him do that.
 
          6       Q.   Right, but did there come a time when he gave you a
 
          7    number?
 
          8       A.   Yes, sir, that's correct.  That's when I called him back
 
          9    because my mother told me to call him back, and I asked, and I
 
         10    said, Uncle Ray, mama said push the caller I.D. to see if there
 
         11    is a number, and he did and he gave me the number.
 
         12       Q.   Did there come a time when you took that number and
 
         13    called the Roanoke Police Department?
 
         14       A.   Yes, sir, that's correct.
 
         15       Q.   And did you give that number to them?
 
         16       A.   Yes, sir.  I called the next day, because it was at
 
         17    night.  The next day I called down to the office of the
 
         18    detective that was in charge.  I didn't talk to Mr. Kahl or
 
         19    nothing.  I talked to somebody and I told them what had
 
         20    happened, told them who I was, and gave them the phone number
 
         21    and told them what had happened and that was it.
 
         22            MR. CONRAD:  No further questions.
 
         23            THE COURT:  Cross?
 
         24            MR. WILLIAMS:  No questions, Mr. Williams.
 
         25            THE COURT:  Thank you, sir.  Call your next witness.
 
 
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          1            MR. CONRAD:  The United States would call Sydney
 
          2    Williams.
 
          3                            SYDNEY WILLIAMS,
 
          4    being first duly sworn, was examined and testified as follows:
 
          5                           DIRECT EXAMINATION
 
          6            BY MR. CONRAD:
 
          7       Q.   Would you tell the jury your name, please?
 
          8       A.   Sydney Williams.
 
          9       Q.   Sydney, are you Robin's brother?
 
         10       A.   Yes, I am.
 
         11       Q.   Where do you live, Sydney?
 
         12       A.   I live at 1441 Leon Street, Northwest, Roanoke,
 
         13    Virginia.
 
         14       Q.   And how long have you lived there?
 
         15       A.   About six, five years.
 
         16       Q.   And do you know Mark Barnette?
 
         17       A.   Yes, I do.
 
         18       Q.   Do you see him the courtroom today?
 
         19       A.   Yes, I do.
 
         20       Q.   Could you point him out and describe him to the jury?
 
         21       A.   The gentleman right there in the middle of the two
 
         22    lawyers with the blue suit coat on.
 
         23       Q.   How do you know Mark Barnette?
 
         24       A.   He was dating my sister.  We used to have family outings
 
         25    together and everything and he came around.
 
 
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          1       Q.   How frequently did you see him?
 
          2       A.   Well, I seen him like maybe once a month or maybe a
 
          3    little bit more than that, because I used to work right around
 
          4    the corner from where they were staying at and I used to go on
 
          5    lunch break and go by there to check on her.
 
          6       Q.   Back in April of 1996, where were you working?
 
          7       A.   April of '96?  At the golf course.
 
          8       Q.   And where was that golf course located?
 
          9       A.   It was located up by -- because like then, see, I was
 
         10    actually living across the corner from them, but then I had
 
         11    moved to the golf course, so that was like maybe two miles away
 
         12    from my house on the other side of town.
 
         13       Q.   And what did you do at the golf course?
 
         14       A.   Actually cut the greens and the intermediates.
 
         15       Q.   And from time to time while you were working at the golf
 
         16    course, would you come home for lunch?
 
         17       A.   Yes, I used to go home for lunch every day.
 
         18       Q.   Now, you remember the fire bombing, do you not?
 
         19       A.   Yes, I was called to the fire.
 
         20       Q.   Sometime after the fire bombing, do you recall coming
 
         21    home for lunch from work and finding anything unusual?
 
         22       A.   Yes.  Well, I had my sister's car parked at my house,
 
         23    because my sister was in the hospital and we was running back
 
         24    and forth up the interstate.
 
         25       Q.   Go ahead and speak up if you can.
 
 
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          1       A.   Okay.
 
          2       Q.   What kind of car did your sister have?
 
          3       A.   She had a green Toyota.
 
          4       Q.   Okay.  And where was your sister when her car was parked
 
          5    at your house?
 
          6       A.   She was in the hospital.
 
          7       Q.   And go ahead, you were about to tell the jury what
 
          8    happened on the day that you came home from the golf course when
 
          9    your sister's car was parked at your house.  Go ahead and tell
 
         10    them.
 
         11       A.   Okay.  Well, like when you come to my house, I had a car
 
         12    facing the carport, so I just walked right by the house and I
 
         13    went in and made me a couple of sandwiches.  And when I came out
 
         14    of the house, you know, because when I walked by the house, I
 
         15    didn't really like look at the front of the car, and I went and
 
         16    made a couple sandwiches and I came back out and I seen the
 
         17    cards on her windshield with the windshield wipers holding the
 
         18    cards on the windshield.
 
         19       Q.   What kind of cards were they?
 
         20       A.   They was like old cards that she had wrote to him like
 
         21    when they was together or having a long distance
 
         22    conversation -- I mean, a long distance relationship.
 
         23       Q.   Okay.  And after you found those cards on her
 
         24    windshield, what did you do?
 
         25       A.   I proceeded to be late for work and went straight down
 
 
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          1    to my mom's to check on her because she had came home then.
 
          2       Q.   Who had come home then?
 
          3       A.   My sister Robin, she had came home from the hospital.
 
          4    My mom was at work and I was at work and everything, so I went
 
          5    straight down there and I checked the house and checked on her.
 
          6    And so I got on the phone and I called --
 
          7       Q.   Now, when you went over to your mother's house, was
 
          8    Robin there alone?
 
          9       A.   Yes.  So then I got on the phone and I called over to my
 
         10    Aunt Cary's house and Uncle Ray was there.  So I got in the car
 
         11    and went and picked him up, and I didn't never tell Robin
 
         12    anything, I just went and got my uncle and picked him up from
 
         13    Aunt Cary's and took him to Robin.  But I had told him
 
         14    everything so he could be right there with her.
 
         15       Q.   Why did you do that?
 
         16       A.   Because I didn't know if he was in town or -- he had to
 
         17    have been in town because the cards wasn't there when I left to
 
         18    go to work that morning.
 
         19       Q.   When you say he, who are you referring to?
 
         20       A.   Mark Barnette.
 
         21       Q.   Did you drop Ray off at your mother's house?
 
         22       A.   At my mother's house and went back and walked back
 
         23    around the side of the house to make sure there wasn't anyone
 
         24    around.
 
         25       Q.   All right.  And what did you do after that?
 
 
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          1       A.   Uncle Ray said he was going to take care of everything
 
          2    and be around the house, so then I just proceeded to go back to
 
          3    work.
 
          4       Q.   Let me hand to you what has been marked for
 
          5    identification as Government's Exhibits 50A, 50B, 50C, 50D, 50E,
 
          6    50F and 50G and ask you, Sydney, if you recognize those
 
          7    exhibits?  Go ahead and look at each one.
 
          8       A.   Yes, sir, these are the same cards, because this one
 
          9    right here was right on the top of the stack of cards that was
 
         10    on the windshield of her car.
 
         11       Q.   Go ahead and speak up if you can.
 
         12       A.   Okay.  These are the same cards, because these was the
 
         13    ones that was on the windshield of her car.
 
         14       Q.   And you are referring to 50B as being the card that was
 
         15    on the top?
 
         16       A.   It was right on the top.
 
         17       Q.   All right.  Now, did you look at those cards when you
 
         18    took them off of your windshield?
 
         19       A.   Yes, I did.
 
         20       Q.   Go ahead and take 50B out of the --
 
         21            MR. CONRAD:  Your Honor, I'd move admission of
 
         22    Government's Exhibit 50A through 50G.
 
         23            THE COURT:  They will be admitted.
 
         24            BY MR. CONRAD:
 
         25       Q.   Turning your attention to Government's Exhibit 50B,
 
 
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          1    would you take it out of the plastic and open it up and look at
 
          2    it.  Now, does that have any names on it?
 
          3       A.   Yes.
 
          4       Q.   What names does it have?
 
          5       A.   They got Robin and Mark.
 
          6       Q.   In a heart?
 
          7       A.   And a heart, it's designed in a heart, forever and ever,
 
          8    and it's got Robin to where she signed it right here.
 
          9       Q.   At the bottom of Government's Exhibit 50B?
 
         10       A.   Yes.
 
         11       Q.   Turn your attention to the front of it.  Is there any
 
         12    writing on the front of the card?
 
         13       A.   Yes.
 
         14       Q.   What is the writing?
 
         15       A.   It's got, why did you lie.
 
         16       Q.   Exclamation point?
 
         17       A.   Exclamation point.
 
         18       Q.   Does it look like there's a signature scrawled at the
 
         19    bottom?
 
         20       A.   It's some kind of signature, but I don't really know
 
         21    what it is, I mean, it's like at the bottom.
 
         22       Q.   Now, if you would with each of the exhibits, would you
 
         23    take them out of the plastic, look at them, see if there is any
 
         24    names on the inside?  Turn your attention to Government's
 
         25    Exhibit's 50F.  Is it signed by anybody?
 
 
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          1       A.   Yes, it's signed by Robin.
 
          2       Q.   And turning your attention to the front of that card, is
 
          3    there any writing on the front of the card?
 
          4       A.   Yes, it is.
 
          5       Q.   What does it say?
 
          6       A.   It says, if you loved him so much, why did you even
 
          7    bother with me.  And it got the same like signature thing in the
 
          8    bottom right here.
 
          9       Q.   Does it appear to be initials at the bottom?
 
         10       A.   Yes, same thing as 50B has on the bottom.
 
         11       Q.   Turning your attention to 50G, anything inside, any
 
         12    names mentioned inside?
 
         13       A.   Yes, it's the same right here about Robin, my sister.
 
         14       Q.   And on the front of it, is there any writing on the
 
         15    front of it?
 
         16       A.   Yes.
 
         17       Q.   What does it say?
 
         18       A.   It says, you never really loved me, and it has the same
 
         19    thing at the bottom that the other two exhibits has.
 
         20       Q.   Let me ask you to look at 50E.
 
         21       A.   Yes.
 
         22       Q.   Signed by Robin?
 
         23       A.   Yes, signed by her.  And the front has the, why wasn't I
 
         24    good enough for you, and it got the same signature thing on
 
         25    there.
 
 
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          1       Q.   Okay.  50D?
 
          2       A.   Yes, this one is the same also.
 
          3       Q.   By Robin?
 
          4       A.   By Robin Williams.
 
          5       Q.   And on the front?
 
          6       A.   It got, you lied to me, with the same signature emblem.
 
          7       Q.   50C?
 
          8       A.   This one isn't signed.
 
          9       Q.   It says, loving you more, Poo?
 
         10       A.   Yes, loving you more, Poo, that's what it says.
 
         11       Q.   On the 21st birthday?
 
         12       A.   Yes, that's what it got, right here.
 
         13       Q.   And on the front -- or turning your attention to the
 
         14    back of that card, is there anything written on the back of the
 
         15    card?
 
         16       A.   Yes, it is, sir.
 
         17       Q.   And what does it say?
 
         18       A.   It's got, Robin, you didn't have to lie about Bennie, if
 
         19    you loved him so much, you should have never fucked our
 
         20    lives -- I mean --
 
         21       Q.   Is it faked?
 
         22       A.   -- faked our love, faked your love for me.
 
         23       Q.   And is there a box with more writing?
 
         24       A.   Yes.
 
         25       Q.   What does it say?
 
 
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          1       A.   These are just a sample of your lies.
 
          2       Q.   And finally, 50A?
 
          3       A.   It has Poo on it also.
 
          4       Q.   And on the front, is there writing on the front?
 
          5       A.   Yes, it is.
 
          6       Q.   What is the writing on the front?
 
          7       A.   You let him come between us, with an exclamation point.
 
          8            MR. CONRAD:  Your Honor, may I pass Government's
 
          9    Exhibits 50A through 50G to the jury?
 
         10            THE COURT:  Yes, sir.
 
         11            BY MR. CONRAD:
 
         12       Q.   Sydney, do you know how long after the fire bombing that
 
         13    you came home and found these cards?
 
         14       A.   I would say approximately about, after the fire bombing,
 
         15    because she had just came home, I would say about maybe three
 
         16    weeks.
 
         17       Q.   Three weeks after?
 
         18       A.   After the fire bombing.
 
         19       Q.   How far was your house at that time from 911 Loudon
 
         20    Avenue?
 
         21       A.   Approximately about maybe two and a half to three miles.
 
         22            MR. CONRAD:  That's all I have, Judge.
 
         23            THE COURT:  Cross?
 
         24            MR. WILLIAMS:  I don't have any questions, thank you,
 
         25    sir.
 
 
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          1            MR. WALKER:  Your Honor, the government would call Mark
 
          2    Etters.
 
          3                              MARK ETTERS,
 
          4    being first duly sworn, was examined and testified as follows:
 
          5                           DIRECT EXAMINATION
 
          6            BY MR. WALKER:
 
          7       Q.   Good morning, sir, will you state your full name,
 
          8    please?
 
          9       A.   Mark Allen Etters.
 
         10       Q.   And Mr. Etters, can you tell us by whom you are employed
 
         11    and what you do for that company?
 
         12       A.   I work for Marriott International at the Courtyard by
 
         13    Marriott located on Arrowood Road.  I'm the general manager of
 
         14    the hotel.
 
         15       Q.   And that hotel which you manage, that's here in
 
         16    Charlotte, is that correct?
 
         17       A.   Yes, sir.
 
         18       Q.   How long have you worked as the general manager of the
 
         19    Courtyard by Marriott hotel at that location?
 
         20       A.   About two and a half years, sir.
 
         21       Q.   What are your general duties as manager of that
 
         22    particular hotel?
 
         23       A.   I run the hotel from the operational standpoint and I
 
         24    report directly to Marriott International about all of the
 
         25    events of the hotel.
 
 
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          1       Q.   As part of your duties and responsibilities, do you have
 
          2    access to former employee files?
 
          3       A.   Yes, sir.
 
          4       Q.   At my request, did I ask you to look into whether or not
 
          5    your hotel at that location at one time or another employed the
 
          6    defendant in this case, Mark, Barnette?
 
          7       A.   Yes.
 
          8       Q.   And would you tell the members of the jury what your
 
          9    investigation showed?
 
         10       A.   We show that he did work at the hotel.  He worked as a
 
         11    night auditor in our hotel, and he left our employment 3-10-95.
 
         12       Q.   And when did he begin employment at that hotel?
 
         13       A.   He was there about a year, I believe it was April
 
         14    of '94.
 
         15       Q.   What were his responsibilities as the night auditor at
 
         16    your hotel?
 
         17       A.   The night auditor, he worked the evening shift, which is
 
         18    from 11:00 at night until 7:00 in the morning, and he reconciles
 
         19    the hotel's receipts on a daily basis.  He was a full-time
 
         20    employee.  He balances the daily records of the hotel.
 
         21       Q.   Who was his direct supervisor while he was at that
 
         22    position?
 
         23       A.   Ed Brumfield was the previous general manager at the
 
         24    hotel.
 
         25       Q.   Was there a Scott Zehner employed by the hotel at that
 
 
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          1    time?
 
          2       A.   Yes, sir, that's correct.
 
          3       Q.   And was he there at the time the defendant was working
 
          4    at your hotel?
 
          5       A.   Yes, sir, he was.
 
          6       Q.   What was Mr. Zehner's position?
 
          7       A.   He was the front desk manager.
 
          8            MR. WALKER:  I don't have any other questions, Your
 
          9    Honor.
 
         10            THE COURT:  Cross?
 
         11            MR. LAUGHRUN:  No questions, Judge.
 
         12            MR. WALKER:  Your Honor, the government calls Lori
 
         13    Quinn.
 
         14                             LORI LEE QUINN,
 
         15    being first duly sworn, was examined and testified as follows:
 
         16                           DIRECT EXAMINATION
 
         17            BY MR. WALKER:
 
         18       Q.   Would you state your full name, please?
 
         19       A.   Lori Lee Quinn.
 
         20       Q.   And Ms. Quinn, by whom are you employed?
 
         21       A.   Camelot Music, Incorporated.
 
         22       Q.   And what do you do for Camelot Music, Incorporated?
 
         23       A.   I'm manager of employee relations and recruiting.
 
         24       Q.   Is Camelot Music, Incorporated, is that a chain music
 
         25    store?
 
 
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          1       A.   Yes, it is.
 
          2       Q.   How many stores do you have in the United States?
 
          3       A.   320.
 
          4       Q.   Do you have a store or stores in Roanoke, Virginia?
 
          5       A.   Yes, we do.
 
          6       Q.   Tell me what your primary responsibilities and duties
 
          7    are with your title at Camelot Music company?
 
          8       A.   I manage the entire employee relations function, which
 
          9    includes overseeing employment records.  I handle all recruiting
 
         10    for corporate positions.
 
         11            THE COURT:  Excuse me just a minute.
 
         12            THE CLERK:  Just back off on the microphone, thank you.
 
         13            THE COURT:  Pull that microphone, just sit back a little
 
         14    bit from it.
 
         15            MR. WALKER:  It's real sensitive.  You can just sit back
 
         16    there and talk.
 
         17            THE WITNESS:  Okay.  Employee issues that arise, I
 
         18    oversee the record retention department of all employment files
 
         19    of --
 
         20            BY MR. WALKER:
 
         21       Q.   Do those include former employment files?
 
         22       A.   Yes.
 
         23       Q.   If someone works for one of your stores, do you keep
 
         24    records of that employee's employment application?
 
         25       A.   Yes, we do.
 
 
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          1            MR. WALKER:  May I approach the witness, Your Honor?
 
          2            THE COURT:  Yes, sir.
 
          3            BY MR. WALKER:
 
          4       Q.   I want to show you what has been marked as Government's
 
          5    Exhibit 13, it consists of three pages, and I will ask you if
 
          6    you can identify that, and if so, what is it?
 
          7       A.   The application for employment from Camelot Music, it's
 
          8    the first two pages, and the third page is the resume.
 
          9       Q.   Okay.  And at my request, did you research your former
 
         10    employee files for possible employment for the defendant in this
 
         11    case, Aquilia Marcivicci Barnette?
 
         12       A.   Yes.
 
         13       Q.   And did you retrieve that particular document, that is,
 
         14    that employment application and resume that have you in front of
 
         15    you?
 
         16       A.   Yes.
 
         17       Q.   Is that document kept on file with your company in the
 
         18    ordinary course of business?
 
         19       A.   Yes.
 
         20            MR. WALKER:  Your Honor, I would move that document into
 
         21    evidence, that being Government's Exhibit 13.
 
         22            THE COURT:  13 will be admitted.
 
         23            BY MR. WALKER:
 
         24       Q.   Referring your attention now to that employment
 
         25    application, does it indicate, if you would, the date that
 
 
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          1    Mr. Barnette first applied or began employment with your company
 
          2    in Roanoke?
 
          3       A.   The application was completed 5-19-95 -- I believe
 
          4    that's 4-19-95.
 
          5       Q.   Did you bring your records with you?
 
          6       A.   Yes, I did.
 
          7       Q.   Do you want to refer to those -- this is a copy, is that
 
          8    correct?
 
          9       A.   Yes, it is.
 
         10       Q.   Do you have the original of that document?
 
         11       A.   Yes.
 
         12       Q.   If you want to refer to those, you may do so.
 
         13       A.   Mr. Barnette started his employment with Camelot on 3-20
 
         14    of '95.
 
         15       Q.   That was March 20th of 1995?
 
         16       A.   Yes.
 
         17       Q.   And at which store was Mr. Barnette employed?
 
         18       A.   Number 185, Valley View Mall in Roanoke, Virginia.
 
         19       Q.   And what was he employed, what was his capacity of
 
         20    employment?
 
         21       A.   He started as a sales associate.
 
         22       Q.   And what happened after that?
 
         23       A.   He was promoted to assistant manager in November of '95,
 
         24    and then his employment was separated January 25th of 1996.
 
         25       Q.   So the employment ended in January of 1996?
 
 
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          1       A.   Yes.
 
          2       Q.   I will give you your documents back.  And in his
 
          3    employment application on the document identified as
 
          4    Government's Exhibit 13, did Mr. Barnette indicate his reasons
 
          5    for seeking employment?
 
          6       A.   Yes.
 
          7       Q.   What was written on the form?
 
          8       A.   I just relocated to Roanoke area, I would love the
 
          9    opportunity to join the Camelot team, I am also a great guy.
 
         10       Q.   Let me ask you one other question.  In the personnel
 
         11    data portion of this application, did he list his home
 
         12    residence?
 
         13       A.   Yes, he did.
 
         14       Q.   And what was the residence listed?
 
         15       A.   1616 Keswick Avenue, Northeast, Roanoke, Virginia,
 
         16    24012.
 
         17            MR. WALKER:  I don't have any other questions, Your
 
         18    Honor.
 
         19            THE COURT:  Cross?
 
         20            MR. LAUGHRUN:  Thank you, Judge Potter, no questions.
 
         21            THE COURT:  Thank you.  Call your next witness.
 
         22            MR. WALKER:  May I pass Government's Exhibit 13 as I
 
         23    call the next witness?
 
         24            THE COURT:  Yes.
 
         25            MR. WALKER:  Your Honor, the government calls Thomas
 
 
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          1    Hodges.
 
          2                            THOMAS H. HODGES,
 
          3    being first duly sworn, was examined and testified as follows:
 
          4                           DIRECT EXAMINATION
 
          5            BY MR. WALKER:
 
          6       Q.   Sir, if you will sit back normally in that chair, that
 
          7    microphone is very sensitive, would you state your full name?
 
          8       A.   Thomas H. Hodges.
 
          9       Q.   And Mr. Hodges, what do you do for a living?
 
         10       A.   Run the Electrolux store in Roanoke.
 
         11       Q.   You run the, pardon me?
 
         12       A.   Electrolux.
 
         13       Q.   And the Electrolux store is what type of business?
 
         14       A.   It's a vacuum cleaner business.
 
         15       Q.   What do you do there at that store, do you have a
 
         16    particular title?
 
         17       A.   I manage the store.
 
         18       Q.   Were you managing the store back in April of 1996 and
 
         19    from that point up until the present time?
 
         20       A.   Yes.
 
         21       Q.   Do you recall at a point back in February of 1996 in
 
         22    which you conducted an interview with an individual named Mark
 
         23    Barnette?
 
         24       A.   Yes.
 
         25       Q.   Do you see that person in the courtroom today?
 
 
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          1       A.   Yes.
 
          2            THE COURT:  Could you speak up just a little bit?
 
          3            THE WITNESS:  Yes.
 
          4            BY MR. WALKER:
 
          5       Q.   As a part of your duties as the manager of the
 
          6    Electrolux store, do you meet with potential employees?
 
          7       A.   Yes, I do.
 
          8       Q.   And explain the process that one would go through to
 
          9    apply for a position with your business.
 
         10       A.   Well, basically you take a resume, find out a little bit
 
         11    about the people, tell them a little bit about what we do, take
 
         12    them out to look at the business, sit down and talk to them.  If
 
         13    they feel like that that's something they could learn to do,
 
         14    would enjoy doing it, then we sit down and fill out a formal
 
         15    application as far as employment.
 
         16       Q.   And did you eventually hire Mr. Barnette?
 
         17       A.   Yes, I did.
 
         18       Q.   In what position was he hired, what was he hired to do?
 
         19       A.   Sales and service.
 
         20       Q.   When you say sales, is that sales to the public?
 
         21       A.   Sales to the public, servicing equipment that's already
 
         22    out there.
 
         23       Q.   Did he complete an employment application with you?
 
         24       A.   Yes, he did.
 
         25            MR. WALKER:  May I approach the witness, Your Honor?
 
 
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          1            THE COURT:  Yes, sir.
 
          2            BY MR. WALKER:
 
          3       Q.   Let me show you Government's Exhibit 14, it consists of
 
          4    two pages, and I will ask you if you can recognize that
 
          5    document, and if so, what is it?
 
          6       A.   Yes, that's the standard documents that they fill out
 
          7    that goes into Atlanta, Georgia as far as employment.
 
          8       Q.   And is that particular application, is that the
 
          9    application that you referred to that you completed with the
 
         10    defendant?
 
         11       A.   Yes, it is.
 
         12       Q.   It consists of two pages, is that correct?
 
         13       A.   Yes.
 
         14       Q.   Okay.  And at what time or what date was that employment
 
         15    application completed?
 
         16       A.   It was on February 15th of '96.
 
         17       Q.   Of 1996?
 
         18       A.   Uh-huh.
 
         19       Q.   Did he indicate what his residence was there in Roanoke
 
         20    when he interviewed with your company?
 
         21       A.   Keswick Avenue, Northwest -- Northeast, Roanoke.
 
         22       Q.   And did he give a number for the Keswick Avenue?
 
         23       A.   1616, I believe is what that says.
 
         24       Q.   At some time, did the defendant's employment with your
 
         25    company come to an end?
 
 
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          1       A.   Yes, it did.
 
          2       Q.   And when was that?
 
          3       A.   That was sometime between April the 10th and the 15th.
 
          4       Q.   Of 1996?
 
          5       A.   Uh-huh.
 
          6       Q.   And did you talk with the defendant about that?
 
          7       A.   He had called and he had equipment checked out and he
 
          8    called me and asked me to come over and pick up the equipment,
 
          9    because he was in the process of trying to move at that
 
         10    particular time.
 
         11       Q.   Did you go over to his apartment on Keswick Avenue?
 
         12       A.   Yes, I did.
 
         13       Q.   What did you see when you went to that location?
 
         14       A.   I saw a loading truck.  I believe it was two gentlemen
 
         15    that was there.  I am thinking one of them is his dad.
 
         16       Q.   Did you see the defendant there?
 
         17       A.   Yes.
 
         18       Q.   And what were they doing with this loading truck?
 
         19       A.   He was getting his equipment out.  I believe there was
 
         20    also a police officer there at the time.
 
         21       Q.   Did you know where the defendant was going to live, did
 
         22    you ever have a conversation with him about that?
 
         23       A.   He wrote down an address of where he was moving to, to
 
         24    send his final check to him.
 
         25       Q.   And what was that, Charlotte, North Carolina?
 
 
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          1       A.   It was in Charlotte, North Carolina.
 
          2            MR. WALKER:  Your Honor, I would move admission of
 
          3    Government's Exhibit 14 and I don't have any other questions of
 
          4    this witness.
 
          5            THE COURT:  It may be admitted.  Cross?
 
          6            MR. LAUGHRUN:  Thank you, Judge Potter.
 
          7                            CROSS-EXAMINATION
 
          8            BY MR. LAUGHRUN:
 
          9       Q.   Mr. Hodge, the address he wrote down, was that 3413 West
 
         10    Boulevard, Charlotte?
 
         11       A.   I believe that's -- I don't have the information with
 
         12    me, I believe it is, but I think you have a copy of the address
 
         13    that he wrote down.
 
         14       Q.   Now, you hired Mark, you never saw any violent
 
         15    tendencies in him, did you?
 
         16       A.   As far as at work in the work situation, I never had any
 
         17    customer complaints or anything of that nature.
 
         18       Q.   And, in fact, he wasn't your best salesmen and wasn't
 
         19    your worst salesmen, is that a fair statement?
 
         20       A.   He really wasn't there long enough to really learn our
 
         21    business, but he was average.
 
         22       Q.   Now, when he got ready to move back to Charlotte, he
 
         23    called you and asked to come to the Keswick apartment to pick up
 
         24    your equipment, did you not?
 
         25       A.   Yes, he did.
 
 
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          1       Q.   That was the equipment you entrusted him to go out and
 
          2    demonstrate the product line, things like that, is that right?
 
          3       A.   That's correct.
 
          4       Q.   No allegation of any theft or anything when he was
 
          5    working with you, is that a fair statement?
 
          6       A.   I think he was like short of one quart of shampoo or
 
          7    something, and he took care of that and we mailed his last check
 
          8    to him.
 
          9       Q.   No other problems with stealing or anything like that,
 
         10    is that correct?
 
         11       A.   Not that I know of.
 
         12       Q.   Mr. Hodge, do you recall an awards banquet in
 
         13    Blacksburg, Virginia that took place while Mark was in your
 
         14    employment and he went with Robin Williams and attended that
 
         15    banquet and you met her, do you recall that incident?
 
         16       A.   I recall the banquet that we went to.  I can't really
 
         17    recall who he brought.  There was a lot of people there, and I
 
         18    can't really recall who he brought with him.
 
         19       Q.   You recall Mark being there, is that right?
 
         20       A.   Uh-huh.
 
         21            MR. LAUGHRUN:  Thank you, Mr. Hodge.  Thank you, Judge
 
         22    Potter.
 
         23            THE COURT:  No redirect?
 
         24            MR. WALKER:  Just briefly, Your Honor.
 
         25                          REDIRECT EXAMINATION
 
 
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          1            BY MR. WALKER:
 
          2       Q.   Mr. Hodges, again on Government's Exhibit 14, when he
 
          3    was applying to your company, did you ask him if he had ever
 
          4    been convicted of a crime?
 
          5       A.   It's listed on the sheet, and I think he checked no.
 
          6       Q.   Look at that document and make sure what he checked.
 
          7       A.   Okay, the section here, have you ever been convicted of
 
          8    a crime, is marked no.
 
          9       Q.   And you also on Page 2 of that form there is a place, is
 
         10    there not, for reasons for leaving prior places of employment,
 
         11    is that right?
 
         12       A.   Yes, sir.
 
         13       Q.   And referring your attention to the first one listed
 
         14    there, former employee, Camelot Music, he indicated a reason for
 
         15    leaving Camelot Music.  What did the defendant list?
 
         16       A.   I can't quite make that out on the copy.  I can't read
 
         17    it.
 
         18            MR. WALKER:  Judge, I don't have any other questions of
 
         19    Mr. Hodges.
 
         20            THE COURT:  Thank you, sir.  Call your next witness.
 
         21            MR. WALKER:  May I have just a moment, Your Honor?
 
         22            (Pause.)
 
         23            MR. WALKER:  Your Honor, the government would call Dan
 
         24    Wilbur.
 
         25                             DANIEL WILBUR,
 
 
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          1    being first duly sworn, was examined and testified as follows:
 
          2                           DIRECT EXAMINATION
 
          3            BY MR. WALKER:
 
          4       Q.   Sir, state your name and tell us what you do for a
 
          5    living.
 
          6       A.   Daniel Wilbur, branch manager for Penske Truck Leasing.
 
          7       Q.   How long have you been a manager for Penske Truck
 
          8    Leasing?
 
          9       A.   I've been the branch manager here in Charlotte for a
 
         10    year.  I've been with Penske for eight years.
 
         11       Q.   And Penske is a -- you can rent moving trucks from your
 
         12    company, is that correct?
 
         13       A.   That's correct.
 
         14       Q.   Was your -- do you work here in a particular office in
 
         15    Charlotte?
 
         16       A.   I work over on I-85 and Billy Graham Parkway.
 
         17       Q.   Was that office open and in business back in April of
 
         18    1996?
 
         19       A.   Yes, it was.
 
         20       Q.   Does your company keep records of when an individual
 
         21    rents a moving truck from your company?
 
         22       A.   Yes, it does.
 
         23       Q.   Are those kept as a part of the ordinary course of
 
         24    business with your company?
 
         25       A.   Yes.
 
 
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          1            MR. WALKER:  May I approach the witness, Your Honor?
 
          2            THE COURT:  Yes, sir.
 
          3            BY MR. WALKER:
 
          4       Q.   I'm going to show you Government's Exhibit 15.  I will
 
          5    ask you to take a look at Government's Exhibit 15, and tell me
 
          6    if you can recognize what that is, and if so, what is it?
 
          7       A.   What we refer to it as a household rental agreement.
 
          8    It's what's filled out when someone rents a truck.
 
          9       Q.   Who is that particular agreement with?
 
         10       A.   The agreement is with Barnette, Aquilia.
 
         11       Q.   And where was the agreement entered into, at which
 
         12    Penske store?
 
         13       A.   That was rented from our agent up in Roanoke, Virginia,
 
         14    3301 Cove Road.
 
         15       Q.   Was it a truck that was rented?
 
         16       A.   I'm sorry?
 
         17       Q.   It was a rental truck that was rented?
 
         18       A.   Yes.
 
         19       Q.   And where was the destination of the rental truck?
 
         20       A.   The destination was to be turned in at 2600 I-85 South.
 
         21       Q.   That's here in Charlotte, correct?
 
         22       A.   That is correct.
 
         23            MR. WALKER:  Your Honor, I would move the admission of
 
         24    that exhibit, Government's Exhibit 15.
 
         25            THE COURT:  All right, sir.  Mr. Wilbur, you are the
 
 
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          1    custodian of those records, are you?
 
          2            THE WITNESS:  Yes, we keep them as well as Atlanta, yes.
 
          3            THE COURT:  They will be admitted.
 
          4            MR. WALKER:  I don't have any other questions, Your
 
          5    Honor.
 
          6            THE COURT:  Cross?
 
          7            MR. WILLIAMS:  No questions.
 
          8            THE COURT:  Thank you, sir, call your next witness, you
 
          9    may step down.
 
         10            MR. CONRAD:  Your Honor, may we take a morning break at
 
         11    this time?
 
         12            THE COURT:  All right, sir.  Little early, but we'll
 
         13    take it.  Members of the jury, do not discuss the case among
 
         14    yourselves.  Go back and see if Ms. Grier has made you some good
 
         15    coffee at this point.
 
         16            Excuse me, did she have an exhibit in her hand, Sammy?
 
         17    Sammy, go back and tell them to bring the exhibit back and put
 
         18    it on the chair.
 
         19            (The Clerk retrieves exhibit from a juror.)
 
         20            (The jury left the courtroom.)
 
         21            THE COURT:  Recess until 10:50.
 
         22            (Brief recess.)
 
         23            THE COURT:  Call the jury.
 
         24            (The jury returned to the courtroom.)
 
         25            THE COURT:  Members of the jury, I may have neglected to
 
 
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          1    tell you, if you have an exhibit which has been passed around to
 
          2    you in your hand whenever we have a recess, just leave it on
 
          3    your chair, because I don't want my exhibits back in the jury
 
          4    room until you get ready for your deliberations.  You will have
 
          5    them all back there for your deliberations, so do not try to
 
          6    take them back and preview them right now.
 
          7            One other thing I want to mention to you as a practical
 
          8    matter, if you go out at lunch, you probably ought to get your
 
          9    raincoat because I understand the it's going to raining hard
 
         10    this afternoon.  It may not be, but that's what the weather man
 
         11    says.
 
         12            All right, call your next witness.
 
         13            MR. CONRAD:  The United States would call Sara
 
         14    Aldridge.
 
         15                             SARAH ALDRIDGE,
 
         16    being first duly sworn, was examined and testified as follows:
 
         17                           DIRECT EXAMINATION
 
         18            BY MR. CONRAD:
 
         19       Q.   Would you state your name for the jury and spell your
 
         20    last name for the court reporter?
 
         21       A.   Sara Aldridge, A-L-D-R-I-D-G-E.
 
         22       Q.   Sarah, how are you employed?
 
         23       A.   I'm a registered nurse at the University of Virginia.
 
         24       Q.   And in what department at the University of Virginia?
 
         25       A.   The burn unit.
 
 
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          1       Q.   How long have you been a registered nurse?
 
          2       A.   Three years.
 
          3       Q.   And have those three years all been in the burn unit?
 
          4       A.   Two and a half of them.
 
          5       Q.   Okay.  And in April of 1996, what were your duties?
 
          6       A.   I was a staff nurse in the burn unit at the university.
 
          7       Q.   And what does a staff nurse in the burn unit at UVA do?
 
          8       A.   We provide total care for burn patients and chronically
 
          9    wound care parents.
 
         10       Q.   When you say total care, what are you referring to?
 
         11       A.   We provide the wound care for the burns, we provide the
 
         12    daily care, the medications, the assessments, the monitoring.
 
         13       Q.   And wound care, what would be involved with wound care?
 
         14       A.   In relation to a burn, we tank our patients each day.
 
         15    That's a process in which we cleanse the wound, remove any dead
 
         16    flesh, repair the wound bed for grafting.
 
         17       Q.   Now, tanking, that's a pretty descriptive term, what is
 
         18    involved in that process?
 
         19       A.   Tanking is a word that's kind of a carry over from years
 
         20    ago when a patient was submerged in a large pool of water.
 
         21       Q.   Uh-huh.
 
         22       A.   The way our unit tanks a person is on a large stretcher
 
         23    that's lined with plastic, take them into a special procedure
 
         24    room in which they are -- we use general flow water to wash down
 
         25    their wounds with an antimicrobial agent called Sure Cleanse.
 
 
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          1    Then we debride or remove the flesh that is not going to heal
 
          2    and rewrap the wounds with various products according to
 
          3    how -- what stage of healing they are in.
 
          4       Q.   And this process, is it a painful process?
 
          5       A.   Yes, sir.  Without medication, it would be very painful.
 
          6       Q.   Is that because of the debriding or the removal of flesh
 
          7    that you were referring to?
 
          8       A.   Not so much the removal of the flesh as it is the depth
 
          9    of the burn.  A first degree burn or what we would think of as a
 
         10    sunburn is very, very painful.  A second degree burn is also
 
         11    painful.  The deeper the burn or the third degree burn in and of
 
         12    itself initially is not painful, because the nerve endings have
 
         13    been destroyed.  We use strong medications and ample medications
 
         14    that are quick acting, that last a very short period of time,
 
         15    and perform what we call conscious sedation.
 
         16       Q.   What kind of medications are those?
 
         17       A.   One medication we use a called Versed.  It is a
 
         18    benzodiazepine that helps to relieve anxiety.  And the other
 
         19    medication that we actually use for pain is Phentanyl, which is
 
         20    an opioid that is kin to morphine, but it's very quick acting.
 
         21       Q.   In April of 1996, do you recall Robin Williams being a
 
         22    burn patient at the burn center in UVA?
 
         23       A.   Yes, sir.
 
         24       Q.   Relate to the jury how you first met her.
 
         25       A.   Our unit is very small.  Our staff works as a very tight
 
 
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          1    team in that each of us help to provide for all of the needs of
 
          2    each patient.  I first met Robin when she was in her room.  She
 
          3    had already received her first tanking.  She was laying in her
 
          4    room very quiet and still.  She was not responsive to any
 
          5    overtures at conversation for several days.  She just was kind
 
          6    of untrusting of us at first.
 
          7       Q.   How frequent were the tanking procedures administered to
 
          8    her?
 
          9       A.   Once a day.
 
         10       Q.   And as a staff nurse, would you have opportunity to be
 
         11    with her during that time period that she was at the burn
 
         12    center?
 
         13       A.   Yes, sir.
 
         14       Q.   Did you have any conversation with her?
 
         15       A.   Yes, sir, I did.
 
         16       Q.   And relate to the jury any conversation that you had
 
         17    with her.
 
         18            MR. LAUGHRUN:  Objection.
 
         19            THE COURT:  Excuse me, I will sustain that unless we get
 
         20    into something more specific.
 
         21            MR. CONRAD:  Thank you, Your Honor.
 
         22            BY MR. CONRAD:
 
         23       Q.   Did you discuss a protection plan with her?
 
         24       A.   Yes.
 
         25       Q.   Describe for the jury what a protection plan is.
 
 
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          1       A.   Near the end of her stay when we are making our final
 
          2    discharge plans, Robin was due for grafting in the next day or
 
          3    two, I took care of her on an evening night shift.  We were
 
          4    talking about her situation and what her plans were for
 
          5    discharge, where she would go.  She described to me --
 
          6            MR. LAUGHRUN:  Objection.
 
          7            THE COURT:  Wait a minute.
 
          8            BY MR. CONRAD:
 
          9       Q.   In the process of discussing this protection plan, did
 
         10    you ask her about the incident which led to her coming to the
 
         11    UVA burn center?
 
         12       A.   Yes, sir.
 
         13       Q.   And what, if anything, did she tell you about that?
 
         14            MR. LAUGHRUN:  Objection.
 
         15            THE COURT:  Overruled.
 
         16            THE WITNESS:  She told me that she had been in a fire,
 
         17    that it had been started by her boyfriend, she had jumped from a
 
         18    window.  She told me that she wasn't sure whether she should
 
         19    jump, whether he would be waiting for her at the bottom or if
 
         20    she should run through the fire, but she realized she would be
 
         21    engulfed had she run through the fire and she had no choice.
 
         22            BY MR. CONRAD:
 
         23       Q.   Did she tell you anything else about the incident
 
         24    itself?
 
         25       A.   That was the basics of it.
 
 
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          1       Q.   Did she tell you anything with respect to her future
 
          2    plans?
 
          3       A.   Yes, sir.
 
          4       Q.   What did she tell you?
 
          5            MR. LAUGHRUN:  Objection.
 
          6            THE COURT:  Overruled.
 
          7            MR. CONRAD:  Go ahead.
 
          8            THE WITNESS:  She told me that she would be going home
 
          9    with family in the Roanoke area or in southwest Virginia area.
 
         10    She told me -- I asked her specifically if she felt that that
 
         11    was far enough way that she would be safe, to which she told me
 
         12    that it wouldn't matter where she went, that she was not going
 
         13    to be safe.
 
         14            BY MR. CONRAD:
 
         15       Q.   Now, you indicated that she was near the end of her
 
         16    stay, ready for grafting, what did you mean by that?
 
         17       A.   When a person receives a third degree burn, the skin
 
         18    will not regenerate, it will not heal, and skin from another
 
         19    area of the body has to be removed and surgically implanted over
 
         20    the area that has been burned.
 
         21       Q.   Now, so do I understand her course of treatment to be
 
         22    one of trying to get the skin to regenerate for the first part
 
         23    of her stay and the second phase being the skin grafting
 
         24    procedures?
 
         25       A.   Robin had several levels of injury.  The first and
 
 
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          1    second degree burns were promoted to heal and regenerate on
 
          2    their own.  The third degree burns that she received primarily
 
          3    on her hands were not going to heal.  It's fairly obvious after
 
          4    the first 48 hours, and then it's preparing the wound bed.  So
 
          5    we did a little of all of it.
 
          6       Q.   Did she eventually undergo skin grafting?
 
          7       A.   Yes, sir.
 
          8       Q.   And what is involved in that?
 
          9       A.   They are taken to the operating room.  Under general
 
         10    anesthesia, skin is removed, skin and muscle tissue if that is
 
         11    needed,  she needed just skin tissue, is removed usually from a
 
         12    leg in the thigh area.  It's then sutured onto the affected
 
         13    area.  As I recall, hers was what we call a split thickness skin
 
         14    graft meaning that it was just lifted up from, say, if this was
 
         15    the leg, and put here on the back of her hand and sewn down with
 
         16    compression dressings to hold it in place until it adhered.
 
         17       Q.   And as part of her discharge plan, did you discuss with
 
         18    her her future rehabilitation plans?
 
         19       A.   Yes, sir.  She said that she would be receiving
 
         20    follow-up care at the university for the foreseeable future.
 
         21            MR. CONRAD:  That's all I have, Judge.
 
         22            THE COURT:  Cross?
 
         23            MR. WILLIAMS:  No questions, Your Honor.
 
         24            THE COURT:  No cross?
 
         25            MR. WILLIAMS:  No questions.
 
 
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          1            THE COURT:  Thank you.  Call your next witness.
 
          2            MR. WALKER:  Your Honor, the government calls Jacob
 
          3    Freshour.
 
          4                          JACOB BOYD FRESHOUR,
 
          5    being first duly sworn, was examined and testified as follows:
 
          6                           DIRECT EXAMINATION
 
          7            BY MR. WALKER:
 
          8       Q.   Sir, if you will have a seat and lean back in that
 
          9    chair, that microphone is very sensitive in front of you, would
 
         10    you state your full name?
 
         11       A.   Jacob Boyd Freshour.
 
         12       Q.   And Mr. Freshour, what do you do for a living?
 
         13       A.   Manage Quik Pawn Shop.
 
         14       Q.   You manage the Quik Pawn Shop?
 
         15       A.   Yes, sir.
 
         16       Q.   How long have you been the manager of the Quik Pawn
 
         17    Shop?
 
         18       A.   Four years.
 
         19       Q.   And that's -- how many locations are there of your
 
         20    business here in Charlotte?
 
         21       A.   Four in Charlotte.
 
         22       Q.   Back in May, and specifically on May 20th and May 21st
 
         23    of 1996, were you the manager of one of the Quik Pawn shops here
 
         24    in Charlotte?
 
         25       A.   Yes, sir.
 
 
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          1       Q.   Which particular store was that, and if you'll raise
 
          2    your voice just a little bit?
 
          3       A.   The freedom Drive branch.
 
          4       Q.   Did you, turning your attention to the morning of
 
          5    May 20th of 1996, did you on that particular morning have
 
          6    occasion to sell a 12-gauge shotgun to an individual at your
 
          7    pawnshop?
 
          8       A.   Yes, sir.
 
          9       Q.   And was that a Stephens 12-gauge shotgun?
 
         10       A.   Yes, sir.
 
         11       Q.   Would you describe, do you remember if it was in the
 
         12    morning or afternoon that you made that sale?
 
         13       A.   It was in the morning, slightly after we opened.
 
         14       Q.   Pardon me?
 
         15       A.   It was in the morning just slightly after we opened,
 
         16    9:30 maybe.
 
         17       Q.   What do you remember about that sale, if you would tell
 
         18    the members of the jury?
 
         19       A.   It was a pretty uncomplicated sale.  The gentleman just
 
         20    came in and said he was looking for a shotgun.  It wasn't
 
         21    rushed.  We just looked at three or four, and that particular
 
         22    one was, you know, the price range he said he was hunting for.
 
         23    He filled out the yellow form, and very little conversation
 
         24    during the sale.
 
         25       Q.   What name did the person give you?
 
 
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          1       A.   Mario Vonkeith Barnette.
 
          2       Q.   And you mentioned that you filled out some forms.  Are
 
          3    there particular firearm forms, Bureau of Alcohol, Tobacco and
 
          4    Firearm forms that you have to fill out when you complete the
 
          5    sale of a firearm?
 
          6       A.   Yes, sir, there is a yellow form on a shotgun that you
 
          7    fill out.
 
          8       Q.   And tell the members of the jury why it's important for
 
          9    your company to fill those out.
 
         10       A.   So we can track the gun.  It establishes, you know, that
 
         11    the person is not a felon or has a record or anything like that.
 
         12       Q.   Did this person present you with some form of
 
         13    identification, the person who called himself Mario Barnette?
 
         14       A.   Yes, sir.
 
         15       Q.   What form of information did he present you on May 20th
 
         16    of 1996?
 
         17       A.   It was from Virginia, a Virginia driver's license.
 
         18       Q.   Did you have him complete the form that you just
 
         19    described?
 
         20       A.   Yes, sir.
 
         21       Q.   And did that individual leave the store with the gun
 
         22    that you sold him?
 
         23       A.   Yes, sir.
 
         24       Q.   Describe that gun, what type of shotgun was that?
 
         25       A.   It with a pump shotgun, a Stephens.
 
 
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          1       Q.   Long barrel shotgun?
 
          2       A.   Long barrel shotgun.
 
          3       Q.   I want to turn your attention now to the next day, that
 
          4    being May 21st of 1996, did you have an occasion to see that
 
          5    same person again at your store?
 
          6       A.   Yes, sir.
 
          7       Q.   What time of day was it that you saw him again?
 
          8       A.   Roughly the same time, 9:30, quarter to 10:00.
 
          9       Q.   Did you wait on that person again?
 
         10       A.   Yes, sir.
 
         11       Q.   What happened on that occasion?
 
         12       A.   We give a warranty on our guns, used guns of a year.
 
         13    And he brought the gun home, said he took it home, it was
 
         14    malfunctioning, there was a broken part on it and wanted to
 
         15    exchange it for another gun.
 
         16       Q.   Did you talk with him about that?
 
         17       A.   Yes, sir.
 
         18       Q.   And did you allow an exchange for another gun?
 
         19       A.   Yes, sir.
 
         20       Q.   Tell the members of the jury about that transaction.
 
         21       A.   He brought the gun in, and we don't have a gunsmith on
 
         22    premise or any way to fire the guns, and so I just exchanged the
 
         23    gun for a Winchester semiautomatic shotgun, long barrel.
 
         24       Q.   And did you have this person who called himself Mario
 
         25    Barnette then fill out a second ATF form that you described?
 
 
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          1       A.   Yes.  Each gun has to have a yellow form.
 
          2            MR. WALKER:  May I approach the witness, Your Honor?
 
          3            THE COURT:  Yes.
 
          4            BY MR. WALKER:
 
          5       Q.   I want to show you, Mr. Freshour, what has been marked
 
          6    as Government's Exhibits 18A and 18B.  Referring your attention
 
          7    first to Government's Exhibit 18A, would you take a look at 18A
 
          8    and tell me if you recognize that document, and if so, what is
 
          9    it?
 
         10       A.   Yes, sir, it's a document to transfer ownership of the
 
         11    shotgun from us to the customer.
 
         12       Q.   And is that the document that you completed on the first
 
         13    sale of the shotgun that you described?
 
         14       A.   Yes, sir.
 
         15       Q.   Now, referring your -- are those the documents that your
 
         16    company keeps in the regular course of business?
 
         17       A.   Yes, sir.
 
         18       Q.   Explain to the members of the jury how those documents
 
         19    are filled out, in other words, do you complete all of the
 
         20    questions or how is that done?
 
         21       A.   No, the customer completes the first half that gives
 
         22    address, the name and the date of the transaction, answers a
 
         23    series of questions and then their signature.  And then below
 
         24    that, we check a box that says they have identified themselves
 
         25    with a form of I.D., fill out the I.D., the shotgun, the model,
 
 
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          1    the serial number if applicable, caliber, Stephens, and stamp it
 
          2    with our gun permit number and sign it and date it.
 
          3       Q.   Now, you said there was a series of questions on here
 
          4    that the buyer, potential buyer fills out.  Does the person have
 
          5    to fill that out before you will sell them the firearm?
 
          6       A.   Yes, and if they fill it out wrong, we won't sell the
 
          7    firearm.
 
          8       Q.   And when you say you fill it out wrong, what do you mean
 
          9    by that?
 
         10       A.   If they answer a question like, are you a fugitive from
 
         11    justice, if they put yes, then we will not sell them a firearm,
 
         12    and we don't allow them to fill out another one.
 
         13       Q.   But when the person answers yes or no to those
 
         14    questions, does your company do anything to verify a yes or no
 
         15    or do you just look for a yes or no?
 
         16       A.   By law, you just look for a yes or no.
 
         17       Q.   All right.  Now, let me ask this:  What are question
 
         18    number 8A, I believe, could you read that question if that's how
 
         19    you normally ask or is asked of the potential buyer?
 
         20       A.   Are you under indictment or information in any court for
 
         21    a crime punishable by imprisonment for a term exceeding one
 
         22    year, or formal accusation of a crime made by a prosecuting
 
         23    attorney as distinguished from an indictment as presented by a
 
         24    Grand Jury.
 
         25       Q.   And that particular form was filled out by the
 
 
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          1    individual that you sold the first shotgun to who gave you the
 
          2    name Mario Vonkeith Barnette, is that correct?
 
          3       A.   Yes, sir.
 
          4       Q.   And how did that person answer that question?
 
          5       A.   No.
 
          6       Q.   And what is the question right underneath that?
 
          7       A.   Have you been convicted in any court of a crime
 
          8    punishable by imprisonment for a term exceeding one year, and
 
          9    then it says no -- yes answer is necessary if the judge could
 
         10    have given you a sentence of more than one year, a yes answer is
 
         11    not required if you have been pardoned for the crime, or the
 
         12    conviction has been expunged or set aside, or you have had your
 
         13    civil rights restored and under the law where the conviction
 
         14    occurred you are not prohibited from receiving or possessing any
 
         15    firearm.
 
         16       Q.   And in response to that question, have you been
 
         17    convicted in any court of a crime punishable by imprisonment for
 
         18    a term exceeding one year, what answer did the person give you?
 
         19       A.   No.
 
         20       Q.   Referring your attention now to the third question, does
 
         21    that read, are you a fugitive from justice?
 
         22       A.   Yes.
 
         23       Q.   And what answer did this person who called himself
 
         24    Mario, what answer did he give?
 
         25       A.   No.
 
 
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          1       Q.   You mentioned that you fill out part of the form.  Which
 
          2    part of that form do you fill out?
 
          3       A.   Section B.
 
          4       Q.   Okay, would you explain that to the members of the jury,
 
          5    how that's done?
 
          6       A.   The first part of Section B, it says to be completed by
 
          7    the transferor or the seller, and it says the person described
 
          8    in Section A is either known to me or has identified himself or
 
          9    herself to me in the following manner.  You know, we do not --
 
         10    we don't ever let anybody check, is known to me.  They always
 
         11    have to have I.D.  And then type of identification, whether it's
 
         12    a driver's license or a state-issued I.D., has to have name,
 
         13    date of birth, place of residence and signature, the number on
 
         14    the identification itself, and then the next section underneath
 
         15    that lists the type of gun it would be, pistol, revolver, rifle,
 
         16    shotgun, et cetera, model number.
 
         17       Q.   Let me slow you down there just a little bit.  Referring
 
         18    your attention first to question number 9, type of
 
         19    identification the potential buyer gives you, is that a block
 
         20    that you complete?
 
         21       A.   Yes, sir.
 
         22       Q.   And this is the form for the first sale, is that
 
         23    correct, on the 20th?
 
         24       A.   Yes.
 
         25       Q.   And did you -- what did you indicate as the form of
 
 
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          1    identification that this person gave you?
 
          2       A.   I put Virginia, and then actually --
 
          3       Q.   Did you put Virginia identification?
 
          4       A.   I put Virginia I.D.  We don't have to notate necessarily
 
          5    D.L. or I.D., we just do it kind of for our records.
 
          6       Q.   Okay.  Describe again briefly the type of shotgun that
 
          7    you sold during the first transaction.
 
          8       A.   It was a Stephens shotgun, model 77-B, 12-gauge, just a
 
          9    regular long barrel pump shotgun.
 
         10            MR. WALKER:  Your Honor, I would move that exhibit into
 
         11    evidence, Government's Exhibit 18A.
 
         12            THE COURT:  Let it be admitted.
 
         13            BY MR. WALKER:
 
         14       Q.   Now, sir, you indicated that you saw the same person the
 
         15    next day, is that correct?
 
         16       A.   Yes, sir.
 
         17       Q.   And you said that was shortly after you opened, is that
 
         18    right?
 
         19       A.   Yes, sir.
 
         20       Q.   And you had him complete the same type of form a second
 
         21    time?
 
         22       A.   Yes, sir.
 
         23       Q.   Referring your attention to Government's Exhibit 18B, is
 
         24    that the second firearm transaction form that you completed with
 
         25    the same person on the 21st, the second day?
 
 
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          1       A.   Yes, sir.
 
          2       Q.   And was that required in order for you to sell the
 
          3    exchange of the first shotgun for the second shotgun?
 
          4       A.   Yes, sir.
 
          5       Q.   And did you go through the same procedure with this
 
          6    person as you had on the day previously?
 
          7       A.   Yes, sir.
 
          8       Q.   In other words, he answered the questions on the top of
 
          9    the form?
 
         10       A.   Yes, sir.
 
         11       Q.   And did you complete the questions on the bottom of
 
         12    form?
 
         13       A.   Yes, sir.
 
         14       Q.   I want to turn your attention to box number 9, where on
 
         15    the second form you wrote in the type of identification the
 
         16    person gave you.  Is that different than the type of
 
         17    identification you placed on Government's Exhibit 18A, the first
 
         18    day of the transaction?
 
         19       A.   The same number, I notated it for our records as a
 
         20    driver's license instead of an I.D.
 
         21       Q.   Could you have made a mistake on that?
 
         22       A.   I would say yes, sir, I would say it's a driver's
 
         23    license.
 
         24       Q.   Okay.  What was the serial number of the second shotgun
 
         25    that you sold the defendant?
 
 
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          1       A.   N 868530.
 
          2       Q.   And was that second shotgun a pump shotgun?
 
          3       A.   No, sir, a semiautomatic.
 
          4       Q.   Was it a long barrel shotgun?
 
          5       A.   Yes, sir.
 
          6       Q.   How did this person pay for these weapons?
 
          7       A.   Cash.
 
          8       Q.   And what was the amount of the sale?
 
          9       A.   With tax, $211.99.
 
         10            MR. WALKER:  Your Honor, I would also move admission of
 
         11    Government's Exhibit 18B.
 
         12            THE COURT:  Let it be admitted.
 
         13            BY MR. WALKER:
 
         14       Q.   Sir, if you were to see a replica or an exact model of
 
         15    the first gun that you sold to this person on the 20th, would
 
         16    you be able to recognize that and indicate that to the jury?
 
         17       A.   Yes, sir.
 
         18            MR. WALKER:  Your Honor, I would ask Agent Modzelewski
 
         19    to assist me in front of the jury and have the witness come
 
         20    down.  I want to show him an exhibit of that type of weapon if I
 
         21    may.
 
         22            THE COURT:  What exhibit number is this?
 
         23            MR. WALKER:  Your Honor, this would be Government's
 
         24    Exhibit 31E-2.
 
         25            THE COURT:  Step down, sir.
 
 
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          1            BY MR. WALKER:
 
          2       Q.   If you will step down and I will ask Agent Modzelewski
 
          3    to come around, and I will show you Government's Exhibit 31E-2.
 
          4    If you will take a look at that item, it's been disengaged, and
 
          5    indicate whether that is exactly like the shotgun that you first
 
          6    sold this person who called himself Mario Vonkeith Barnette?
 
          7       A.   Yes.
 
          8       Q.   Okay, if you would turn around to the members of the
 
          9    jury.
 
         10       A.   Yes, sir.
 
         11       Q.   And that's a pump action shotgun, is that correct?
 
         12       A.   Yes.
 
         13       Q.   You may return to your seat.
 
         14            MR. WALKER:  I don't have any other questions for this
 
         15    witness, Your Honor.
 
         16            THE COURT:  All right, sir.  Cross?
 
         17                            CROSS-EXAMINATION
 
         18            BY MR. WILLIAMS:
 
         19       Q.   Mr. Freshour, your shop is in Charlotte, North Carolina?
 
         20       A.   Yes, sir.
 
         21       Q.   You were selling a gun to somebody with an
 
         22    identification from Roanoke, Virginia?
 
         23       A.   Yes, sir.
 
         24       Q.   Did you ask that person why he was buying a gun in
 
         25    Charlotte, North Carolina when he had a license and
 
 
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          1    identification from Virginia?
 
          2       A.   No, sir.  With a shotgun, as long as you live in a
 
          3    bordering state, you can purchase a shotgun in any bordering
 
          4    state to your state.
 
          5       Q.   When you take these applications and you sell people
 
          6    guns, the purpose of the application and the questions in the
 
          7    application is to inform you, if I'm correct, and correct me if
 
          8    I'm wrong, that you want to know something about this person
 
          9    before you decide whether or not to sell them a gun, correct?
 
         10       A.   Yes, sir.
 
         11       Q.   And on that application, you have questions about their
 
         12    prior criminal record and other things about the person,
 
         13    correct?
 
         14       A.   Yes, sir.
 
         15       Q.   Do you rely 100 percent on the answers that these people
 
         16    give you before you decide to sell them a weapon?
 
         17       A.   Yes, sir, that's the law.
 
         18       Q.   That's the law.  Did you or do you make any attempts
 
         19    whatsoever to go down to the police department with these
 
         20    applications and check the police records to see if they have a
 
         21    record, either here or in the State of Virginia?
 
         22       A.   No, sir, we do what is required by law.
 
         23       Q.   If you knew that Mr. Barnette had a record, as indicated
 
         24    on the questionnaire, would you have sold him that gun?
 
         25       A.   No, sir.
 
 
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          1            MR. WILLIAMS:  No further questions.
 
          2            THE COURT:  Redirect?
 
          3            MR. WALKER:  Briefly.
 
          4                          REDIRECT EXAMINATION
 
          5            BY MR. WALKER:
 
          6       Q.   On both of the forms, did the person who bought those
 
          7    two guns from you indicate his home address?
 
          8       A.   Yes, sir.
 
          9       Q.   And what, if you will tell the jury, what address was
 
         10    listed?
 
         11       A.   1616 Keswick Avenue, Northeast, Roanoke, Virginia.
 
         12       Q.   And is that on both forms?
 
         13       A.   Yes, sir.
 
         14            MR. WALKER:  Your Honor, I would ask permission to pass
 
         15    these to the jury.
 
         16            THE COURT:  You haven't moved the admission of 31E-2
 
         17    yet, I don't think.
 
         18            MR. WALKER:  As well, move that into admission as well.
 
         19            THE COURT:  Very well, it will be admitted.
 
         20            MR. WALKER:  I don't have any other questions, Your
 
         21    Honor.
 
         22            THE COURT:  Thank you, sir, you may come down.  Call
 
         23    your next witness.
 
         24            MR. CONRAD:  United States would caller Earlene
 
         25    Thompson.
 
 
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          1                            EARLENE THOMPSON,
 
          2    being first duly sworn, was examined and testified as follows:
 
          3                           DIRECT EXAMINATION
 
          4            BY MR. CONRAD:
 
          5       Q.   Would you please state your name for the jury, spelling
 
          6    your last name for the court reporter?
 
          7       A.   Earlene Thompson, T-H-O-M-P-S-O-N.
 
          8       Q.   Ms. Thompson, where do you live?
 
          9       A.   904 Loudon, apartment A.
 
         10       Q.   You are going to have to speak up a little bit, okay?
 
         11       A.   904 Loudon in Roanoke, apartment A.
 
         12       Q.   And how long have you lived there?
 
         13       A.   Two years.
 
         14       Q.   And were you living there in April of 1996?
 
         15       A.   Yes, I was.
 
         16       Q.   How long had you been living at that -- strike that.
 
         17            How long had you been living there in April of 1996?
 
         18       A.   About a month.
 
         19       Q.   About a month?
 
         20       A.   Uh-huh.
 
         21            MR. CONRAD:  May I approach the witness, Your Honor?
 
         22            THE COURT:  Yes, sir.
 
         23            BY MR. CONRAD:
 
         24       Q.   Ms. Thompson, can you come off the witness stand and
 
         25    come up with me, please?
 
 
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          1       A.   (Witness complies.)
 
          2       Q.   I'm going to show you what has been marked for
 
          3    identification as Government's Exhibits 21P, 21O, 21R and 21Q,
 
          4    and do you recognize those photographs?
 
          5       A.   (Witness nods head.)  This is my apartment there.
 
          6       Q.   Are these aerial photographs and ground-level
 
          7    photographs of Loudon Avenue?
 
          8       A.   Yes, it is.
 
          9       Q.   And do they fairly and accurately show your
 
         10    neighborhood?
 
         11       A.   Yes, it does.
 
         12            MR. CONRAD:  Your Honor, move admission of Government's
 
         13    Exhibits 21P, O, R and Q.
 
         14            THE COURT:  They will be admitted.
 
         15            MR. CONRAD:  Okay -- stay right here.
 
         16            BY MR. CONRAD:
 
         17       Q.   Turning your attention to Government's Exhibit 21P, and
 
         18    if you would stand on the side right here so all of the jurors
 
         19    can see, would you show the jury where your apartment is?
 
         20       A.   Right here and right here (indicating), right here and
 
         21    right here, in front of this car.
 
         22       Q.   Now, is it a duplex?
 
         23       A.   Yes, it is.
 
         24       Q.   Do you know Ms. Bertha Williams?
 
         25       A.   Yes, I do.
 
 
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          1       Q.   Can you show the jury where on this photograph
 
          2    Ms. Williams' house is?
 
          3       A.   Right there, there, (indicating) there and down the
 
          4    street.
 
          5       Q.   And do you know who lives -- this is a duplex right
 
          6    here, is that correct?
 
          7       A.   Yes.
 
          8       Q.   As you face Loudon Avenue, do you live on the left or
 
          9    the right?
 
         10       A.   Left.
 
         11       Q.   Okay.  So you -- on this side of the building
 
         12    (indicating)?
 
         13       A.   Right.
 
         14       Q.   Do you know who lives on your right?
 
         15       A.   Yes.
 
         16       Q.   Who lives there?
 
         17       A.   Sonji Hill.
 
         18       Q.   Has she lived there the whole that you've been there?
 
         19       A.   Yes.
 
         20       Q.   Does anyone live with you at 904 Loudon Avenue?
 
         21       A.   My daughters.
 
         22       Q.   How old are they?
 
         23       A.   They're 8 and 12.
 
         24       Q.   Does anybody live with Ms. Hill as far as you know in
 
         25    the other apartment?
 
 
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          1       A.   Her daughters.
 
          2       Q.   How old are her daughters?
 
          3       A.   12 and 3, I think.
 
          4       Q.   Go ahead and have a seat.
 
          5            Ms. Thompson, you are going to have to speak up and into
 
          6    the microphone.  Do you remember the day that Robin was killed?
 
          7       A.   Yes, I do.
 
          8       Q.   What is the first thing that you remember about that?
 
          9       A.   Waking up to gunshots.
 
         10       Q.   And tell the jury, what brought that to your attention?
 
         11       A.   I heard gunshots, and I got up immediately and went to
 
         12    the door.
 
         13       Q.   Do you know what time of day that was?
 
         14       A.   It was in the morning.  It was about 6:30, 7:00 o'clock,
 
         15    something like that.
 
         16       Q.   And what were you doing at that time?
 
         17       A.   I was in bed.
 
         18       Q.   And you heard gunshots, so what did you do after you
 
         19    heard the gunshots?
 
         20       A.   Immediately I got up, went to the front door with the
 
         21    phone in my hand, because there is a club that's right across
 
         22    the street.
 
         23       Q.   You are going to have to speak up, Earlene.
 
         24       A.   There is a club that was right across from where I lived
 
         25    at, so I thought it was that.  So I had the phone in my hand
 
 
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          1    calling 911 saying I heard gunshots.
 
          2       Q.   Okay.
 
          3       A.   I had the door open at the time that I said I heard
 
          4    gunshots.
 
          5       Q.   What did you see as you looked out the door?
 
          6       A.   I saw this guy standing in Ms. Williams' yard.
 
          7       Q.   And is that across the street?
 
          8       A.   It's across the street.
 
          9       Q.   And when you saw the guy standing in Ms. Williams' yard,
 
         10    what was he doing?
 
         11       A.   He was facing the side door.  He had the gun in his
 
         12    hand.  I could see Ms. Williams standing in her door holding a
 
         13    child.
 
         14       Q.   Was she in the front door?
 
         15       A.   No, the side door.
 
         16       Q.   And she was holding her child?
 
         17       A.   She was holding a child.
 
         18       Q.   And then what did you did you see?
 
         19       A.   Then I saw Robin run out the front door, and she ran
 
         20    across the street up the side of my yard.
 
         21       Q.   Had you met Robin before?
 
         22       A.   No, I've seen her and I've even waved and spoke to her.
 
         23       Q.   And she ran out the front door, what did you see next?
 
         24       A.   He was coming across the street.  He was like in the
 
         25    middle of the street.  And I looked dead in his face, I looked
 
 
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          1    at him and he had the gun.
 
          2       Q.   When you say he had the gun --
 
          3       A.   He had the gun like at a jar, it was like at an angle.
 
          4       Q.   Uh-huh.
 
          5       A.   And I just immediately hung up the phone and closed the
 
          6    door.
 
          7       Q.   And why did you hang up the phone and close the door?
 
          8       A.   Scared.
 
          9       Q.   Okay.  As I understand your testimony, you saw -- did
 
         10    you see him run from the side door?
 
         11       A.   He didn't really run, he kind of like trotted across the
 
         12    street.
 
         13       Q.   And how far ahead of him was Robin when she started
 
         14    running out the front door?
 
         15       A.   Not that far, not that far.  She was like up the side of
 
         16    my house when he was coming towards the street.
 
         17       Q.   Okay.  So again, you are on the left side of that
 
         18    duplex, and she is running up on your side --
 
         19       A.   On my side.
 
         20       Q.   -- of the house?
 
         21       A.   Yes.
 
         22       Q.   And where was he when she was on your side?
 
         23       A.   He was coming up towards the street.  He probably had
 
         24    touched the street part by that time.
 
         25       Q.   Did you make eye contact with him?
 
 
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          1       A.   Yes, I did.
 
          2       Q.   Describe that.
 
          3       A.   Very scary feeling.  I don't know, I just reacted so
 
          4    fast.  Automatically, I just hung up the phone and closed the
 
          5    door.
 
          6       Q.   When you made eye contact with him, where was the gun
 
          7    pointed?
 
          8       A.   Towards my house.
 
          9       Q.   And after you closed the door, what did you do?
 
         10       A.   I had went like, I went to my kitchen and I ran back
 
         11    outside.  I went back outside.
 
         12       Q.   Okay.
 
         13       A.   The police had called me back to my house and I hung up
 
         14    the phone again on them, because I guess I wasn't ready to talk
 
         15    to them just yet.  I called them right back as I got down my
 
         16    steps, and he was dragging her down the street on the side of
 
         17    the house.
 
         18       Q.   When you called the police back, what did you say?
 
         19       A.   I said, there is a man out here with a gun, he is
 
         20    pulling this girl, you know, I told them that he is shooting out
 
         21    here.  He was shooting.  He had shot up in the air.
 
         22       Q.   Now, when you first came back out, you said did you go
 
         23    down your steps?
 
         24       A.   I went down my steps.
 
         25       Q.   There is a flight of steps that leads to the landing to
 
 
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          1    your duplex, is that correct?
 
          2       A.   Yes.
 
          3       Q.   And when you went down those steps, what did you see?
 
          4       A.   I saw him pulling her down the side of the street on the
 
          5    right.
 
          6       Q.   Okay.  If you would come back off of the stand, please.
 
          7       A.   (Witness complies.)
 
          8       Q.   Using Government's Exhibit 21O, can you stand on the
 
          9    side and show the jury where he was pulling Robin when you saw
 
         10    him from your steps?
 
         11       A.   Right here, down this street.
 
         12       Q.   Now, where was he when you first saw him?
 
         13       A.   Right here (indicating) on the side of the house.
 
         14       Q.   And then when you were hanging up the phone and you made
 
         15    eye contact with him?
 
         16       A.   Right here (indicating).
 
         17       Q.   And where was Robin when you said that she ran up the
 
         18    side?
 
         19       A.   Right here (indicating).
 
         20       Q.   And now when you saw him pulling Robin, what else did
 
         21    you see?
 
         22            THE COURT:  I'm sorry, I can't hear.
 
         23            MR. CONRAD:  Go ahead and take the stand.
 
         24            THE WITNESS:  Ms. Williams was terrified, she was
 
         25    hollering, somebody help.
 
 
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          1            BY MR. CONRAD:
 
          2       Q.   And where was she when she was hollering that?
 
          3       A.   She was up in the yard part.
 
          4       Q.   So she'd moved from the side door to her --
 
          5       A.   She was right with her the whole time almost.  She was
 
          6    right there with him when he was bringing her back down the
 
          7    street.
 
          8       Q.   And what did you observe next?
 
          9       A.   When he shot, she turned to run, and when she ran to the
 
         10    side of my yard, he shot her in the back.
 
         11       Q.   How far was she from her mother, Mrs. Williams, when she
 
         12    was shot?
 
         13       A.   She wasn't that far from her.
 
         14            THE COURT:  Can you gauge it from here to the back of
 
         15    the courtroom, will that help, would you say it's as far as the
 
         16    back of the courtroom?
 
         17            THE WITNESS:  No, it wasn't that far.  She was close.
 
         18    She was close as -- it was maybe to the guy in the white shirt.
 
         19            BY MR. CONRAD:
 
         20       Q.   As close as the court reporter is to you today?
 
         21       A.   Yeah.
 
         22            MR. WILLIAMS:  Objection, there's not what she said.
 
         23            THE COURT:  I will sustain the leading.  Maybe you can
 
         24    rephrase your question.
 
         25            BY MR. CONRAD:
 
 
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          1       Q.   Can you use anything in the courtroom to judge the
 
          2    distance between Mrs. Williams and Robin when she was shot?
 
          3       A.   Yeah, me the guy sitting in the second row, it was maybe
 
          4    about that distance.  It wasn't as far at all.
 
          5       Q.   And could you tell whether or not he was saying anything
 
          6    to Robin before he shot her?
 
          7       A.   No.  If he was, I didn't realize.
 
          8       Q.   And do you how many times he shot her?
 
          9       A.   He just shot her once in the back.
 
         10       Q.   And then what happened after that?
 
         11       A.   I was in shock after that.  I remember Ms. Williams
 
         12    running up on the porch, somebody help her daughter.  Basically
 
         13    it just went like that.  She was just asking somebody to help
 
         14    her daughter.  I was in a state of shock after that happened
 
         15    because I couldn't believe it happened, but I see him as he was
 
         16    leaving.
 
         17       Q.   Tell the jury about that.
 
         18       A.   When he shot her, like I say, he didn't run, he just
 
         19    trotted like to the car.  And the car was like across the street
 
         20    from where I lived at in a side alley.  He backed up and left.
 
         21       Q.   And where was the car in relation to Mrs. Williams'
 
         22    house?
 
         23       A.   If you go through the alley, if you go right --
 
         24       Q.   There's an alley?
 
         25       A.   It's like an alley -- I never been back there, but I
 
 
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          1    know it's some type of alley that's right there.
 
          2       Q.   Behind Mrs. Williams' house?
 
          3       A.   It went right behind Mrs. Williams' house.  It's an
 
          4    abandoned house that's like on the corner, I guess was right in
 
          5    there behind that house.
 
          6       Q.   Okay.  And he trotted in that direction?
 
          7       A.   Yes.
 
          8       Q.   What did you observe next?
 
          9       A.   He got in the car, backed the car up next thing I
 
         10    notice.  And by then, I guess it took maybe a minute or so more
 
         11    for the ambulance finally got there.
 
         12       Q.   Now, as he backed the car up, did you see the car?
 
         13       A.   Somewhat.  I didn't really see.
 
         14       Q.   What did you see?
 
         15       A.   I saw the back of the car.
 
         16       Q.   And what did it look like?
 
         17       A.   Now, that, I couldn't tell you.
 
         18            MR. CONRAD:  Your Honor, at this point, may I have
 
         19    permission to play a 911 tape?
 
         20            THE COURT:  Yes, sir.
 
         21            MR. CONRAD:  Your Honor, if I could move into evidence,
 
         22    Government's Exhibits 20A and 20C.
 
         23            AGENT MODZELEWSKI:  Ladies and gentlemen, please take
 
         24    your headphones, turn the power on so the green light is
 
         25    visible, place them on your head so the blue bulb can be in
 
 
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          1    contact with the antenna, please.  Again, if you have any
 
          2    problems, please raise your hand if you cannot hear anything.
 
          3            (Tape played for the jury.)
 
          4            THE COURT:  Mr. Conrad, I'm not sure you moved the
 
          5    admission of these.
 
          6            MR. CONRAD:  I thought I had, Your Honor.
 
          7            THE COURT:  If you did, I missed it.  All right, let
 
          8    them be admitted, 20A and 20C.
 
          9            BY MR. CONRAD:
 
         10       Q.   Ms. Thompson, did you recognize your voice on that 911
 
         11    tape?
 
         12       A.   Yes, I did.
 
         13            MR. CONRAD:  That's all I have.
 
         14            THE COURT:  All right, cross?
 
         15                            CROSS-EXAMINATION
 
         16            BY MR. WILLIAMS:
 
         17       Q.   Ms. Thompson, I just have one question and I want to
 
         18    make sure I understand it, and I appreciate it.  I'm sorry to
 
         19    have to ask you this question.  When you said how far was
 
         20    Ms. Williams from Robin when the shot was fired, I believe you
 
         21    referred to someone on the jury in a white shirt.  Is that --
 
         22    are you referring to the second juror from the end on the front
 
         23    row?
 
         24       A.   Yes, I'm referring to somewhere in that distance.
 
         25       Q.   Between that juror and you?
 
 
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          1       A.   Yes.
 
          2            MR. WILLIAMS:  No further questions, I appreciate it.
 
          3                          REDIRECT EXAMINATION
 
          4            BY MR. CONRAD:
 
          5       Q.   What is that a measure -- that distance is for what?
 
          6       A.   When he --
 
          7       Q.   How far were you from where Robin was shot?
 
          8       A.   I was standing on -- I was -- it's at the end of the
 
          9    sidewalk of my yard, so maybe it's the same distance.  That's
 
         10    where I was standing.
 
         11       Q.   Okay, thank you.
 
         12            MR. CONRAD:  That's all I have.
 
         13            THE COURT:  Thank you, come down.  Call your next
 
         14    witness.
 
         15            MR. CONRAD:  The United States would call Sonji Hill.
 
         16                            SONJI MARIE HILL,
 
         17    being first duly sworn, was examined and testified as follows:
 
         18                           DIRECT EXAMINATION
 
         19            BY MR. CONRAD:
 
         20       Q.   Ma'am, would you state your name for the jury?
 
         21       A.   Sonji Marie Hill.
 
         22       Q.   And Ms. Hill, where do you live?
 
         23       A.   904 Loudon Avenue, apartment B.
 
         24       Q.   How long have you lived there?
 
         25       A.   I've lived there about five years.
 
 
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          1       Q.   And who do you live there with?
 
          2       A.   I live there with my three daughters.
 
          3       Q.   And what are their ages?
 
          4       A.   I have a set of twins, they are 11, and a 3-year-old.
 
          5       Q.   And you said you've lived there for about five years?
 
          6       A.   Yes, I have.
 
          7       Q.   So in June of 1996, that's where you lived?
 
          8       A.   Yes, I did.
 
          9       Q.   Let me turn your attention to the morning of June 22nd,
 
         10    1996.  Did anything happen on that morning, unusual?
 
         11       A.   June 22nd?
 
         12       Q.   Yes?
 
         13       A.   No.
 
         14       Q.   The day that -- I'm sorry, June 21st?
 
         15       A.   Yes.
 
         16       Q.   The day that Robin was killed?
 
         17       A.   Yes.
 
         18       Q.   What do you first remember about that day?
 
         19       A.   I was on the phone with a coworker and we were talking,
 
         20    and I heard a noise outside and I told her -- I had extended
 
         21    cord on my phone, and I took the phone to the front door and I
 
         22    saw Robin come out of the house and the accused go in front of
 
         23    me.
 
         24       Q.   Let me ask you a couple questions about that, and if you
 
         25    could, speak up into the microphone.  Where do you work?
 
 
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          1       A.   Where do I work?
 
          2       Q.   Where did you work at that time?
 
          3       A.   At Allstate.
 
          4       Q.   And you were on the phone with someone at your
 
          5    employment?
 
          6       A.   She was at home.  She lived in Rocky Mount.
 
          7       Q.   And when you went to the front door, tell the jury what
 
          8    you did and what you saw.
 
          9       A.   I hung up with her and called 911.
 
         10       Q.   You called 911?
 
         11       A.   Yes, I did.
 
         12       Q.   Why did you do that?
 
         13       A.   Because Ms. Williams asked me to.
 
         14       Q.   What did you do next, what did you see next?
 
         15       A.   From after I called 911?
 
         16       Q.   Uh-huh.
 
         17       A.   I saw -- after I said they passed me, she came to the
 
         18    bottom of the steps.  And then once he caught her over the hill,
 
         19    they came back down the hill and they were parallel to me.
 
         20       Q.   Now, go ahead step by step, tell the jury what you saw,
 
         21    where were you -- were you at the --
 
         22       A.   I was actually outside on the porch.
 
         23       Q.   Okay.  And you are on the right side of a duplex?
 
         24       A.   I'm on the right side, yes, I am.
 
         25       Q.   It's on the corner of Loudon and what other street?
 
 
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          1       A.   Corner of Loudon and 9th Street.
 
          2       Q.   9th Street?
 
          3       A.   Yes.
 
          4       Q.   And what did you see when you were on your porch?
 
          5       A.   From my porch, I would have to turn to my right, and he
 
          6    had brought her back parallel to me, which it's my porch then
 
          7    it's a grassy area and then it's the street.
 
          8       Q.   Now, when you say he had brought her back --
 
          9       A.   He had her by her hair and was dragging her back down.
 
         10       Q.   Where did you first see him having her by her hair,
 
         11    where was he?
 
         12       A.   He was up towards the hill.
 
         13       Q.   On 9th Street?
 
         14       A.   Yes.  There is like a little hill that you have to go
 
         15    up.
 
         16       Q.   Away from Loudon Avenue?
 
         17       A.   Away from, towards the back of the apartment.
 
         18       Q.   And what did you observe from the point in time where
 
         19    you saw him having her by her hair, from that point forward,
 
         20    what did you see?
 
         21       A.   I saw him literally dragging her back to be parallel
 
         22    with myself.  And they were having conversation, but I
 
         23    can't -- I couldn't hear.
 
         24       Q.   You heard conversation, but you couldn't hear what --
 
         25       A.   Right.
 
 
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          1       Q.   Exactly what it was?
 
          2       A.   Right.  I was more so focusing on Ms. Williams calling
 
          3    me.
 
          4       Q.   So at the same time that you saw him grabbing her by her
 
          5    hair, Ms. Williams was talking to you as well?
 
          6       A.   Yes.  She was in the grass.  He was this way and she was
 
          7    sort of toward --
 
          8       Q.   What was Ms. Williams saying to you?
 
          9       A.   She was telling me, he has my baby, he has my baby.
 
         10       Q.   Other than having her by her hair, did he have anything
 
         11    in his hands?
 
         12       A.   He had the gun in his hand.
 
         13       Q.   Describe the gun.
 
         14       A.   It was long, it was --
 
         15       Q.   It was a long gun?
 
         16       A.   It was a long gun, uh-huh.
 
         17       Q.   And what was he doing with the gun?
 
         18       A.   He had the gun down, and then --
 
         19       Q.   Did there come a time when you called 911?
 
         20       A.   Yes.  When I was on the phone with 911, I guess he
 
         21    realized that I was calling and I was asking what was his name,
 
         22    what was his name.  And then when he realized that I had the
 
         23    phone in my hand, he pointed the gun up to me and told me if I
 
         24    didn't hang the mother-fucking phone up, that he was going to
 
         25    shoot me, and then I hung the phone up.
 
 
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          1       Q.   Where was he when he said that?
 
          2       A.   He was actually in the street, grassy area part of
 
          3    the -- on the road.
 
          4       Q.   Was it on the 9th Avenue side?
 
          5       A.   Yes, it was on 9th Avenue side.
 
          6       Q.   How far was he from you when he told you all that?
 
          7       A.   He was the length of the corner of the apartment to the
 
          8    grass, which would have been 50 feet, if that.
 
          9       Q.   Did you make eye contact with him?
 
         10       A.   I don't know if it would be eye contact.  I saw him, but
 
         11    I didn't see him.  You know how you look but you don't?
 
         12       Q.   And you heard him?
 
         13       A.   Yes, I heard him.
 
         14       Q.   And what was your reaction to that?
 
         15       A.   My reaction was I hung the phone up and went in the
 
         16    home.
 
         17       Q.   Why did you do that?
 
         18       A.   He scared me.
 
         19       Q.   Did you think he was going to shoot you?
 
         20       A.   Yes.
 
         21            MR. WILLIAMS:  Objection.
 
         22            THE COURT:  Overruled.
 
         23            BY MR. CONRAD:
 
         24       Q.   Did you think he was going to shoot you?
 
         25       A.   Yes, I did.
 
 
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          1       Q.   Was the gun pointed in your direction?
 
          2       A.   Yes, it was.
 
          3       Q.   Now, you hung up the phone, went inside, what did you do
 
          4    then?
 
          5       A.   Once I got inside, I have a front window and I have a
 
          6    side window, and when I got inside, I pulled the -- I have
 
          7    miniblinds, and I pulled it down.  And when I pulled it down,
 
          8    then that's when he shot her.
 
          9       Q.   Okay.  And did you have anymore contact with 911?
 
         10       A.   Yes, after -- directly when I hung up with them, they
 
         11    called me back.  So enough time for me to get -- step back in
 
         12    the house, they called me right back.
 
         13       Q.   Are you on the phone with 911 when the shooting
 
         14    occurred?
 
         15       A.   Yes, I was.
 
         16       Q.   Where were your children at that time?
 
         17       A.   My youngest was still asleep and the twins were in the
 
         18    living room with me.
 
         19       Q.   And what did you next observe?
 
         20       A.   In terms of after he shot her?
 
         21       Q.   You indicated that you pulled the blinds down?
 
         22       A.   I pulled the blinds down, and when he put the gun -- he
 
         23    let her go and she sort of casually walked away, she didn't run
 
         24    away, she casually walked away.  And he cocked the gun, and
 
         25    evidently it jammed the first time, and he cocked it again and
 
 
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          1    shot her.  The way my apartment is, the walls are very thin, so
 
          2    you can --
 
          3       Q.   Now, when he shot her, how far away from her was he?
 
          4       A.   In distance to pull the gun up, I mean.
 
          5       Q.   Pardon me?
 
          6       A.   In distance for him, enough for her to walk away the
 
          7    first time, to cock away.  I mean, it couldn't have
 
          8    been -- feet.
 
          9       Q.   A matter of feet?
 
         10       A.   A matter of feet.
 
         11       Q.   When was Mrs. Williams at this time?
 
         12       A.   She was close to her daughter.
 
         13       Q.   How close?
 
         14       A.   Close, close, close enough, not close enough to save
 
         15    her, but close enough.
 
         16       Q.   As best you can in measurement terms, was she close
 
         17    enough to touch her daughter?
 
         18            MR. WILLIAMS:  Objection, leading.
 
         19            THE COURT:  Overruled.
 
         20            BY MR. CONRAD:
 
         21       Q.   Take your time.  Did you hear my question?
 
         22       A.   Yes, I did.
 
         23       Q.   Just take your time.
 
         24       A.   Yes, she was close enough to touch her daughter.
 
         25       Q.   Now, after you heard those shots, did you hear
 
 
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          1    Ms. Williams say anything?
 
          2       A.   He shot my baby.
 
          3       Q.   Did she say that once or more than once?
 
          4       A.   More than once.
 
          5       Q.   What happened after that?
 
          6       A.   After that, he just casually walked away.  Once he got
 
          7    past Loudon, he trotted to the car, which the car was in --
 
          8    there is an alley behind Ms. Williams' home, and the car was in
 
          9    the alley.  And from there -- I'm sorry.
 
         10       Q.   Go ahead, so he -- do I -- he walked a certain distance
 
         11    and then trotted a certain distance?
 
         12       A.   Right.
 
         13       Q.   How far did he walk?
 
         14       A.   I believe it was -- it wasn't like he just directly
 
         15    darted off, it was more so a casual walking I guess once he
 
         16    realized then to where he was standing to the corner of my yard,
 
         17    and then from the corner of my yard, that's when he trotted.
 
         18       Q.   And can I ask you to come off of the witness stand for a
 
         19    second.  Let me show you Government's Exhibit 210, this aerial
 
         20    photograph right here, can you show the jury where your
 
         21    apartment is?
 
         22       A.   Right here (indicating).
 
         23       Q.   And can you show the jury where the shooting occurred?
 
         24       A.   Right here (indicating).
 
         25       Q.   And can you show the jury where he walked to and where
 
 
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          1    he ran to or trotted to?
 
          2       A.   He walked here and trotted here, almost to this point
 
          3    here (indicating).
 
          4       Q.   Is this the alley that you were referring to?
 
          5       A.   Yes.
 
          6       Q.   Does it go behind Mrs. Williams' house?
 
          7       A.   Yes.
 
          8       Q.   And did you see a car in that alley?
 
          9       A.   Yes.
 
         10       Q.   Where did you first see the car in the alley?
 
         11       A.   It was back here (indicating).
 
         12       Q.   So he reversed out of the alley?
 
         13       A.   Yes.
 
         14       Q.   Then what did he do?
 
         15       A.   He went that way.
 
         16       Q.   Describe the car for the jury.
 
         17       A.   It was a blue Honda hatchback.
 
         18       Q.   Ms. Hill, if you would keep your voice up as best you
 
         19    can.
 
         20       A.   Okay, I'm sorry.
 
         21       Q.   Did I ask you to listen to a 911 recording last night?
 
         22       A.   Yes, you did.
 
         23       Q.   And what was that recording of?
 
         24       A.   Of my conversation with the dispatcher.
 
         25       Q.   Okay.  And did you recognize your voice?
 
 
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          1       A.   Yes, I did.
 
          2            MR. CONRAD:  Your Honor, permission to play 911 tape.
 
          3            THE COURT:  Yes, sir.
 
          4            MR. CONRAD:  Now, for the record, if I can move into
 
          5    admission Government's Exhibit 20B, which is a transcript of the
 
          6    911 phone call.
 
          7            THE COURT:  Mr. Conrad, I'm sorry, I had the earphones
 
          8    on and I didn't hear what you said.
 
          9            MR. CONRAD:  I'm moving admission of Government's
 
         10    Exhibit 20B, which is the transcript of a 911 call.
 
         11            THE COURT:  All right, sir, 20B, move the admission of
 
         12    that, it will be admitted.
 
         13            AGENT MODZELEWSKI:  Ladies and gentlemen, please turn
 
         14    your headphones back on so the green light is visible, put the
 
         15    headphones on your head.  Again, if you have any problems during
 
         16    the play back, please raise your hand.
 
         17            (Tape played for the jury.)
 
         18            BY MR. CONRAD:
 
         19       Q.   Ms. Hill, is that an accurate recording of your first
 
         20    911 call?
 
         21       A.   Yes, it is.
 
         22       Q.   It was disconnected at the point where the tape stopped?
 
         23       A.   Yes.
 
         24       Q.   Tell the jury why it was disconnected.
 
         25       A.   Because he told me to hang up the phone.
 
 
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          1       Q.   What did he tell you?
 
          2       A.   When I hung up?
 
          3       Q.   You hung up the phone, and why did you hang it up?
 
          4       A.   Because he told me to hang it up.
 
          5       Q.   And what were his exact words?
 
          6            MR. WILLIAMS:  Objection, asked and answered.
 
          7            THE COURT:  Overruled.
 
          8            BY MR. CONRAD:
 
          9       Q.   Go ahead, what were his exact words to you?
 
         10       A.   Hang up the mother-fucking phone or I will shoot you.
 
         11       Q.   And so that's when it disconnected?
 
         12       A.   That's when I disconnected it, yeah.
 
         13       Q.   Now, did there come a time when they called you back?
 
         14       A.   Yes, they called me directly back.
 
         15            AGENT MODZELEWSKI:  Put your headphones back on,
 
         16    please.
 
         17            (Tape played for the jury.)
 
         18            (Relative escorted from the courtroom.)
 
         19            MR. WILLIAMS:  Your Honor, defense counsel would like to
 
         20    be heard in the absence of the jury.
 
         21            THE COURT:  All right, sir, at the side-bar.
 
         22            MR. WILLIAMS:  Well, I don't --
 
         23            THE COURT:  Members of the jury, excuse us for a few
 
         24    moments, please.  Do not discuss the case among yourselves while
 
         25    you are out.
 
 
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          1            (The jury left the courtroom.)
 
          2            THE COURT:  Mr. Williams?
 
          3            MR. WILLIAMS:  If Your Honor please, during the playing
 
          4    of that 911 tape, I looked back and observed the family of Robin
 
          5    Williams, and I understand and I empathize and I don't blame
 
          6    them for reacting the way they are reacting.  So please forgive
 
          7    me, but I'm representing my client and I'm trying to make sure
 
          8    he gets a fair trial, Judge.  And Robin Williams' brother
 
          9    starting pounding the seat and he was rocking back and forth and
 
         10    becoming very agitated and I understand him doing so.  The
 
         11    marshal, one or two of the marshals had to go over to the family
 
         12    and try to quiet.  One of the marshals took the brother out of
 
         13    the courtroom.  This was going on while this tape was being
 
         14    played in a very loud, screeching manner.
 
         15            The jury recognized what was happening.  The jury
 
         16    members looked over and observed this.  And Your Honor, we have
 
         17    previously requested that all members of the family and everyone
 
         18    else be sequestered from the courtroom for this very reason,
 
         19    Your Honor.  And with all great due respect to the victim's
 
         20    family, and I have great respect for their loss and I'm sorry
 
         21    for it, but I must on behalf of my client object again, renew
 
         22    our motion for sequestration, not allow the families in here
 
         23    because of the terribly emotional reaction that goes on in this
 
         24    kind of thing.  The jury sees it, they are affected by it, I
 
         25    would respectfully argue.  I would have to make a motion at this
 
 
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          1    point for a mistrial, because of this outburst and because of
 
          2    this happening.
 
          3            THE COURT:  Mr. Conrad, Mr. Walker?
 
          4            MR. WALKER:  Your Honor, I became aware that the marshal
 
          5    had one of Robin's brothers when they were simply just walking
 
          6    up the aisle out of the courtroom.  I then looked at the jury to
 
          7    see what, if any, of them were paying attention to that.  My
 
          8    notion was the jury was paying attention to the tape.  In any
 
          9    event, Your honor, whether they looked up and saw Robin
 
         10    Williams' brother being taken out of the courtroom by the
 
         11    marshal or not, the marshal did what he is instructed to do, he
 
         12    was removed quickly as I noticed it, and the jury should just be
 
         13    told to disregard if there was an outburst in the courtroom.
 
         14            Your Honor, these family members can't be expected --
 
         15    first of all, they have a right to attend this trial and they
 
         16    have a right to hear this testimony, and I would ask you to deny
 
         17    Mr. Williams' motion.  And I understand why he made the motion,
 
         18    but they have a right to be here, Your Honor, and it's -- they
 
         19    also have a right to their feelings.  And we will talk to them
 
         20    about how they are going to express those, but we would ask you
 
         21    to deny that motion for a mistrial.  And if Your Honor sees fit
 
         22    or even sees the need just to simply tell the jury to not be
 
         23    cognizant of any reaction in the courtroom.  I mean, Your Honor
 
         24    has probably seen that before and instructed juries like that
 
         25    before, and that's simply the way to remedy the situation.
 
 
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          1            THE COURT:  Well, I was listening to the tape myself or
 
          2    reading the transcript rather as well as some other things here,
 
          3    and I became aware whenever I did glance up and saw the marshal
 
          4    over there that something was happening.  I did look at the jury
 
          5    at the same time.  I think the way I observed it at that time,
 
          6    they were concentrating on the transcript as well as the tape.
 
          7            I'm going to deny the motion for the sequestration of
 
          8    the family members, because I think they're entitled to be
 
          9    here.  I'm going to deny the motion for a mistrial.  I will
 
         10    instruct the jury to disregard anything of an emotional nature
 
         11    be demonstrated by the family of Robin Williams.
 
         12            All right, call the jury.
 
         13            (The jury returned to the courtroom.)
 
         14            THE COURT:  Members of the jury, this tape which was
 
         15    just played, of course, had some -- sort of like the TV programs
 
         16    you listen to that have a great deal of emotional activity on
 
         17    the part of the caller, or the witness here.  In the event that
 
         18    you did observe any emotions on the part of the Robin Williams
 
         19    family who is seated in the courtroom, I ask you or I direct you
 
         20    to disregard that in anything.  It's not part of the case.  Part
 
         21    of the case is the evidence in the case and not what their
 
         22    reaction is in this matter.  Thank you.
 
         23            BY MR. CONRAD:
 
         24       Q.   Ms. Hill, are you ready to proceed?
 
         25       A.   Yes.
 
 
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          1       Q.   There is a part in that 911 call in which dispatcher was
 
          2    asking you what his name was, and you were screaming out, what
 
          3    is his name, what is his name.  Do you recall that part of the
 
          4    911 call?
 
          5       A.   Yes.
 
          6       Q.   Did someone answer you?
 
          7       A.   Yes, they did.
 
          8       Q.   Who was that?
 
          9       A.   Ms. Williams.
 
         10       Q.   And what did she tell you?
 
         11       A.   Mark.
 
         12       Q.   And did she tell you Barnette as well?
 
         13       A.   Yes, she gave his whole name.
 
         14       Q.   Now, there was another voice I heard in the background
 
         15    of the tape saying something over and over again.  Do you know
 
         16    who that voice belonged to and what she was saying?
 
         17       A.   Yes, the voice belongs to Ms. Williams and she was
 
         18    saying, Jesus.
 
         19       Q.   Does that audio tape that we just played, does that
 
         20    accurately record what you were saying on that morning?
 
         21       A.   Yes.
 
         22            MR. CONRAD:  That's all I have, Your Honor.
 
         23            THE COURT:  Cross?
 
         24            MR. WILLIAMS:  No questions, Your Honor.
 
         25            THE COURT:  Thank you, sir.  Call your next witness.
 
 
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          1    Thank you, ma'am, you may step down.
 
          2            MR. WALKER:  Your Honor the government would call
 
          3    Officer Dean.
 
          4                         DANIEL C. DEAN
 
          5    being first duly sworn, was examined and testified as follows:
 
          6            DIRECT EXAMINATION.
 
          7            BY MR. WALKER:
 
          8       Q.   Would you state your full name?
 
          9       A.   Daniel C. Dean.
 
         10       Q.   What do you do for a living?
 
         11       A.   Patrolman with the Roanoke City Police Department.
 
         12       Q.   How long have you been a patrol officer with the Roanoke
 
         13    City Police Department?
 
         14       A.   6 years.
 
         15       Q.   I want to turn your attention back to the early morning
 
         16    hours of June 22nd, 1996, did you -- do you remember the events
 
         17    of that morning?
 
         18       A.   Yes, I do.
 
         19       Q.   Were you on duty at that time?
 
         20       A.   Yes, I was.
 
         21       Q.   Were you in the city limits of Roanoke, Virginia?
 
         22       A.   Yes.
 
         23       Q.   Where were you -- well, did you receive a particular
 
         24    call concerning the 900 block of Loudon Avenue at some point
 
         25    that morning?
 
 
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          1       A.   Yes, I did.  I was sitting in the parking lot of the
 
          2    YMCA which was located on the corner of Church Avenue and 5th
 
          3    Street Southwest.
 
          4       Q.   How far is that in your estimation from the 900 block of
 
          5    Loudon Avenue?
 
          6       A.   Approximately eight-tenths of a mile.
 
          7       Q.   When you say you were sitting at that location, were you
 
          8    in a marked police car?
 
          9       A.   Yes.
 
         10       Q.   And you were in uniform just as you are today?
 
         11       A.   Yes.
 
         12       Q.   What happened?
 
         13       A.   I heard a dispatch come over the radio about a person
 
         14    brandishing a firearm on the 900 block of Loudon Avenue
 
         15    Northwest.
 
         16       Q.   What time was it when you first heard that call?
 
         17       A.   Approximately 7:10 a.m.
 
         18       Q.   Did you go -- when you say you heard a dispatch, was
 
         19    that a direction for you to go to that location, or what do you
 
         20    mean by that?
 
         21       A.   That was put out to all of the units, I was a south side
 
         22    unit, south side of the city unit, I was not going to respond to
 
         23    that, that would have been a north side unit call.
 
         24       Q.   Did you respond any way?
 
         25       A.   Yes, I did, the call escalated from a person with a
 
 
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          1    weapon to subjects fighting.  Eventually the dispatcher advised
 
          2    that shots had been fired and a person was down.  At that time I
 
          3    activated my blue lights and siren and proceeded to the 900
 
          4    block of Loudon.
 
          5       Q.   How long did it take you to get to that part of the
 
          6    Loudon?
 
          7       A.   Probably less than a minute.
 
          8       Q.   And when you arrived, what did you see?
 
          9       A.   I arrived on the scene, I pulled my vehicle into the 800
 
         10    block of Loudon Avenue and stopped.  I saw a couple of people on
 
         11    the street and one person was on the ground near the
 
         12    intersection of 9th and Loudon.
 
         13       Q.   At the intersection of 9th and Loudon?
 
         14       A.   Yes.
 
         15       Q.   When you say on the ground, describe the position that
 
         16    the person was in?
 
         17       A.   At that intersection there is a small grassy area little
 
         18    that meets with the road intersection there.  This person was
 
         19    laying on the hill with her head -- it was a female -- with the
 
         20    head toward the roadway, her feet were towards the top of the
 
         21    hill on her back.
 
         22       Q.   Did you later identify that person?
 
         23       A.   Yes, it was Robin Williams.
 
         24       Q.   Did you run up to Robin Williams at that point?
 
         25       A.   Yes, I exited my vehicle, proceeded up to the lady that
 
 
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          1    was on the ground.  There was another lady standing very close
 
          2    to her.  As I walked up, I did notice a red shotgun shell on the
 
          3    ground near the lady that was laying on the ground.
 
          4       Q.   After you noticed that shotgun shell, did you go over to
 
          5    Robin Williams?
 
          6       A.   Yes, I did.
 
          7       Q.   And describe for the jury exactly what you did and what
 
          8    you saw?
 
          9       A.   As I approached her, I leaned down close to her, I
 
         10    didn't get on the ground, I leaned over her.  And at that time
 
         11    she had made a slow gasp, and then she stopped, she made another
 
         12    longer gasp of air, kind of gurgled, and then her body went limp
 
         13    and there was no emotion from her at that time.
 
         14       Q.   You heard no more breath, is that correct?
 
         15       A.   No, sir.
 
         16       Q.   You say there was another female there, did you see a
 
         17    person there that you later identified as Robin's mother, Bertha
 
         18    Williams?
 
         19       A.   Yes, she was there.  She was the female standing near
 
         20    Ms. Robin Williams on the ground.
 
         21       Q.   And what did you notice about her when you first
 
         22    arrived?
 
         23       A.   She was very hysterical, crying, she kept telling me to
 
         24    not let Robin die.  She said repeatedly, don't let her die.  I
 
         25    tried to assure her that rescue was already on the way, that
 
 
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          1    they would be here shortly.  She just continued to say, don't
 
          2    let her die, don't let my baby die.
 
          3       Q.   Did you notice any wounds on Robin's body when you
 
          4    looked at her?
 
          5       A.   Yes, she had a large wound to the upper left chest.
 
          6       Q.   What did you do with Ms. Bertha Williams at that time?
 
          7       A.   At that time to secure our scene, I wanted to get her
 
          8    away to an area away from this area so that we could secure the
 
          9    scene.  She took my arm near the elbow very tightly, just
 
         10    escorted her across the street to her residence at 911.  The
 
         11    whole time she was still begging me to help her daughter.
 
         12       Q.   Did you finally get her to -- get Ms. Williams to 911
 
         13    Loudon Avenue?
 
         14       A.   Yes, I did.  Once we got to 911 Loudon, we walked up on
 
         15    the porch, there was a chair there.  I had her sit down in the
 
         16    chair, she was still very emotional, crying, she asked he to say
 
         17    a prayer with her.  I did that at that time, right there on the
 
         18    porch.  At that time rescue had arrived and was attending to
 
         19    Robin Williams.
 
         20       Q.   Did other officers also arrive?  You said rescue
 
         21    arrived, did other officers eventually arrive?
 
         22       A.   Yes.  As we were walking across the street other
 
         23    officers were arriving on the scene beginning to secure the
 
         24    area --
 
         25       Q.   When you say --
 
 
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          1       A.   -- and question witnesses.
 
          2       Q.   I'm sorry?
 
          3       A.   Question another people that were in the area.
 
          4       Q.   When you say secure the area, tell the members of the
 
          5    jury exactly what that entails?
 
          6       A.   Basically what we want to do is find out what area the
 
          7    scene would entail, and we use police tape as police line,
 
          8    yellow tape to try to mark off which areas to keep people out of
 
          9    the areas in case there is evidence that we may need to collect
 
         10    so it isn't tampered with or lost.
 
         11            MR. WALKER:  May I approach the witness, Your Honor.
 
         12            THE COURT:  Yes.
 
         13            MR. WALKER:  Your Honor, may the officer come down and
 
         14    join me in front of the jury briefly.
 
         15            THE COURT:  Yes.
 
         16            BY MR. WALKER:
 
         17       Q.   Sir, if you'd come down and join me in front of the
 
         18    jury, and I want to refer your attention to Government's Exhibit
 
         19    21Q, and we will start with this end of the jury and proceed
 
         20    down to that end of the jury.  Would you indicate on
 
         21    Government's Exhibit 21Q where you saw the body of Robin
 
         22    Williams when you arrived on the scene?
 
         23       A.   Approximately this area here (indicating).
 
         24       Q.   Is that the intersection of 9th and Loudon?
 
         25       A.   Yes, it is.
 
 
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          1       Q.   And if you will walk with me down to this end of the
 
          2    jury, and if you stand on the other side of the court reporter
 
          3    and if I will stand here, if you point to the members of the
 
          4    jury on 21Q where you saw the body of Robin Williams?
 
          5       A.   In this area here (indicating).
 
          6       Q.   You may return to your seat.
 
          7            MR. WALKER:  Nothing else Your Honor.
 
          8            THE COURT:  Any cross?
 
          9            MR. WILLIAMS:  No, sir.
 
         10            THE COURT:  Thank you sir, call your next witness.
 
         11            MR. CONRAD:  Officer C.R. Lee.
 
         12                                C.R. LEE
 
         13    being first duly sworn, was examined and testified as follows:
 
         14            DIRECT EXAMINATION.
 
         15            BY MR. CONRAD:
 
         16       Q.   Sir, would you state your name and occupation for the
 
         17    jury?
 
         18       A.   Officer Lee of the Roanoke City Police Department.
 
         19       Q.   Officer Lee, how long have you been employed by the
 
         20    Roanoke Police Department?
 
         21       A.   About seven years now.
 
         22       Q.   And in June of 1996, how were you employed?
 
         23       A.   As a patrol officer.
 
         24       Q.   In what district?
 
         25       A.   Work district A which is located northwest city.
 
 
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          1       Q.   Okay.  On June 22nd, 1996, did you get a call with
 
          2    reference to activity at 9 -- at the 900 block of Loudon Avenue?
 
          3       A.   Yes, I did.
 
          4       Q.   Would you relate to the jury what call you received?
 
          5       A.   Yes, sir.  I was stationary in the 3000 block of Salem
 
          6    Turnpike northwest of the city, received a call from dispatch
 
          7    advising that a subject had entered a residence and then had a
 
          8    female run out of the residence.  At that time, we started going
 
          9    closer, the dispatch center advised us again that a female
 
         10    subject had a gun.  At that time we started to run nearer and
 
         11    found that the dispatch advised us that a male subject had
 
         12    female subject in custody holding at gun point, at that time, we
 
         13    were still drawing --
 
         14       Q.   Still what?
 
         15       A.   Growing closer to the scene.
 
         16       Q.   Okay.
 
         17       A.   And the dispatch came back and advised that male subject
 
         18    had discharged a firearm and the female subject was down.  At
 
         19    that time, we arrived on the scene, arrived to the 900 block of
 
         20    Loudon Avenue northwest, observing at the intersection of 9th
 
         21    and Loudon a female victim lying on the ground.
 
         22       Q.   All right, and what did you do at that time?
 
         23       A.   At that time, I went over to her and tried to see if
 
         24    there was any type of life in the victim by trying to check her
 
         25    pulse.  Observing nothing, I stayed with her until the rescue
 
 
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          1    squad got there.
 
          2       Q.   Okay, and what did you observe when you stayed with the
 
          3    victim?
 
          4       A.   As I noticed her, I noticed her arms was over her head
 
          5    as she laid on her back, her left leg was pinned up under her,
 
          6    and a large wound on her side of her chest.
 
          7       Q.   Okay.  Did you notice anybody else around her?
 
          8       A.   Not at that time, sir.
 
          9       Q.   What did you do next?
 
         10       A.   After the rescue took her over I proceeded to get
 
         11    witnesses from the area.
 
         12       Q.   Did there come a time when you went to 911 Loudon
 
         13    Avenue?
 
         14       A.   That's correct.
 
         15       Q.   Why did you do that?
 
         16       A.   Going back to reenact what may have happened, to see the
 
         17    mother also that was inside the residence.
 
         18       Q.   And did you meet with the mother?
 
         19       A.   Yes, sir, I did.
 
         20       Q.   And what if anything did you say to her?
 
         21       A.   I -- she was very emotional, and she advised me that
 
         22    Mr. Barnette was the suspect in this offense.
 
         23       Q.   And what did you do next?
 
         24       A.   At that time, I relayed that information to my sergeant
 
         25    and helped secure the rest of the area.
 
 
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          1       Q.   Okay.  Did you make a visual observation of the
 
          2    residence at 911 Loudon?
 
          3       A.   Yes, sir, I did.
 
          4       Q.   What did you see?
 
          5       A.   At the back door, noticed that there were, at a side
 
          6    entrance way there were three large gun shot holes in the
 
          7    doorway.  I also noticed on the door there was a footprint where
 
          8    it appeared that somebody had kicked that door.  There was
 
          9    inside the residence there was debris from some type of gun
 
         10    shot, bullet or shrapnel from that into some pillows, on door
 
         11    framing, chairs, tables.  It was more or less through the
 
         12    apartment.  At that time we tried to comfort the mother also.
 
         13       Q.   And then did you also begin the process of interviewing
 
         14    witnesses or potential witnesses to the incident?
 
         15       A.   Yes, sir, I did.
 
         16            MR. CONRAD:  Your Honor that's all I have.
 
         17            MR. WILLIAMS:  No questions.
 
         18            THE COURT:  Any cross?
 
         19            MR. WILLIAMS:  (Witness shakes head.)
 
         20            MR. CONRAD:  Your Honor, may we have a scheduling
 
         21    side-bar at this time?
 
         22            THE COURT:  Yes, sir
 
         23                   (bench conference not recorded. ).
 
         24            THE COURT:  Members of the jury, we have some matters to
 
         25    take up right now, so we will let go ahead and let you go to
 
 
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          1    lunch, and ask you to come back if you would at 1:30 please.
 
          2            Do not discuss the case among yourselves while you are
 
          3    out or with anyone outside of the courtroom.  Again if you have
 
          4    any exhibits in your hand or transcripts or anything, leave
 
          5    those in the chairs and they will be there when you come back.
 
          6    Thank you.
 
          7            (The jury left the courtroom.)
 
          8            THE COURT:  Mr. Conrad, I believe at side-bar you said
 
          9    something about scheduling.
 
         10            MR. CONRAD:  Yes, Your Honor, thank you for allowing me
 
         11    to be heard on the schedule.  We went through 14 witnesses this
 
         12    morning, we made sure that we had 20 witnesses to testify here
 
         13    today, and five of those witnesses we decided in light of the
 
         14    evidence coming in so quickly and some stipulations that we have
 
         15    entered into with the defendant, that we could excuse five of
 
         16    the witnesses.  So we've been through 19 of the 20 witnesses
 
         17    that we anticipated calling today.
 
         18            This afternoon, we have two witnesses both lengthy
 
         19    concerning the shooting at 911 Loudon Avenue, and other than
 
         20    some stipulations, that's it with respect to that part of the
 
         21    indictment, except for Dr. Oxley who is medical examiner in
 
         22    Roanoke.  This morning I fully expected Dr. Oxley to be here and
 
         23    prepared to testify.  This afternoon, I was informed that he is
 
         24    testifying in state court and that the earliest flight he can
 
         25    get to be here to testify in this court is 7:30 in the morning,
 
 
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          1    and so we made arrangements for him to be here ready to testify
 
          2    at 9:00 tomorrow.  But he can't get here any sooner.
 
          3            THE COURT:  Okay, how long will the two witnesses you
 
          4    have, how long will they take this afternoon.
 
          5            MR. CONRAD:  I think no longer than two hours total, and
 
          6    I would hate to get into the evidence about the murder which
 
          7    occurred in Charlotte and make the jury go back to the medical
 
          8    examiner to testify about that findings in Roanoke.
 
          9            THE COURT:  Are you including cross-examination in there
 
         10    as well.
 
         11            MR. CONRAD:  If the cross-examination goes like it's
 
         12    been going since yesterday, yes.
 
         13            THE COURT:  Maybe something different with this one.
 
         14            MR. CONRAD:  I can also tell the Court, if the Court
 
         15    will permit us not to delay putting on the Charlotte evidence
 
         16    until tomorrow, I am confident that we can put all of that
 
         17    evidence on tomorrow and be done tomorrow.
 
         18            THE COURT:  Well, we will hold you to that schedule.
 
         19    See you at 1:30.
 
         20            MR. LAUGHRUN:  Could I put on the record, all that was
 
         21    discussed in the side-bar was scheduling, nothing else was
 
         22    discussed and you told us you would send the jury out and put it
 
         23    on the record which Mr. Conrad did and that was all that was
 
         24    discussed at the side-bar.
 
         25            THE COURT:  You're just completing the record?
 
 
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          1            MR. LAUGHRUN:  Yes, sir.
 
          2            THE COURT:  Thank you sir, recess until 1:30.
 
          3            (Lunch recess.)
 
          4            MR. WALKER:  Your Honor, may I address the Court?
 
          5            THE COURT:  We don't have the defendant up here yet.
 
          6    We're waiting for the defendant.
 
          7            Okay.  Let me put mine on the record first.
 
          8                      (The defendant is present.)
 
          9            THE COURT:  I'm going to put something on the record.
 
         10    Mr. Williams had raised a point about the family over here being
 
         11    emotional during the playing of the tape, and I can understand
 
         12    why they would be emotional; however, I also understand that the
 
         13    defendant was crying and making sniffling noises back and
 
         14    forth.  I just want to put that on the record, that happened,
 
         15    this type of thing, it's going the happen when evidence of this
 
         16    type comes up.
 
         17            All right.  What did you want, Mr. Walker?
 
         18            MR. WALKER:  Your Honor, it is the subject of the
 
         19    stipulation, the parties have agreed to Exhibit 19, which is an
 
         20    enlarged exhibit that we have over here of the map showing North
 
         21    Carolina, Virginia, and Tennessee.  We would move that in.  That
 
         22    is Exhibit 19.  I don't intend to pass it to the jury at the
 
         23    moment, but I would --
 
         24            THE COURT:  Wait a minute.
 
         25            MR. WALKER:  It Exhibit no. 19.
 
 
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          1            THE COURT:  19?  The map of North Carolina?
 
          2            MR. WALKER:  Yes, Your Honor.
 
          3            THE COURT:  That's stipulated, and you are going to
 
          4    admit that?
 
          5            MR. WALKER:  Right.  It also contain parts of Virginia
 
          6    and parts of eastern Tennessee as well.
 
          7            THE COURT:  Okay.  Getting back once again to this
 
          8    emotional business, I didn't observe either one of them, either
 
          9    the defendant or the family, because I was, I guess reading the
 
         10    transcript and looking at the jury.  I usually look at them more
 
         11    than I look at anybody else to see what's going on.  And I don't
 
         12    think they did, as I understand it, as I recall.  They were more
 
         13    concentrating on the transcript, and that thing was so loud, I
 
         14    guess they couldn't hear anything.
 
         15            All right.  Call your next witness.  Wait a minute.
 
         16    Call the jury.
 
         17       (The jury returned to the courtroom.)
 
         18            THE COURT:  All right.  I hope everyone had a nice lunch
 
         19    and had time to have lunch.
 
         20            You may call your next witness.
 
         21            MR. WALKER:  Your Honor, the government would call
 
         22    Officer Sacra.
 
         23                             CHAD RYAN SACRA,
 
         24    being first duly sworn, was examined and testified as follows:.
 
         25            DIRECT EXAMINATION
 
 
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          1            BY MR. WALKER:
 
          2       Q.   Sir, would you state your full name and tell us what you
 
          3    do for a living?
 
          4       A.   I'm Officer Chad Ryan Sacra of the Roanoke City Police
 
          5    Department.
 
          6       Q.   And what do you do as a Roanoke City police officer?
 
          7       A.   I'm an evidence technician.  I've been in that capacity
 
          8    for five years.
 
          9       Q.   Would you please explain to the members of the jury what
 
         10    your duties and responsibilities are as an evidence technician?
 
         11       A.   As an evidence technician, I respond to any major crime
 
         12    scenes.  Upon my arrival I search the area for pertinent
 
         13    evidence; identify it as such; document it, both in writing and
 
         14    with photographs; I collect the evidence; I process the evidence
 
         15    for fingerprints; I package the evidence for later lab
 
         16    submissions if necessary.
 
         17       Q.   Were you on duty in that capacity during the early
 
         18    morning hours of June the 22nd, 1996?
 
         19       A.   I was.
 
         20       Q.   What time did you arrive at work that particular
 
         21    morning, if you recall?
 
         22       A.   I arrived at work approximately 10 minutes to 7:00 in
 
         23    the morning.
 
         24       Q.   Did you shortly after you arrived become aware of a call
 
         25    concerning the 900 block of Loudon Avenue there in Roanoke,
 
 
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          1    Virginia?
 
          2       A.   I did.  At approximately 20 minutes after 7:00 that
 
          3    morning, dispatch contacted me in the office; they advised me at
 
          4    that time that there was a shooting that I had been requested
 
          5    on.
 
          6       Q.   What did you do once dispatch made that request of you?
 
          7       A.   Once that request was made, I entered the evidence van
 
          8    at the police department; I drove to the location at Ninth and
 
          9    Loudon.
 
         10       Q.   Did you go to that location alone, when you say you were
 
         11    in the evidence van?
 
         12       A.   Yes, I did.
 
         13       Q.   When you got to that location, tell the members of the
 
         14    jury what you saw.
 
         15       A.   When I arrived at that location, the Roanoke Emergency
 
         16    Medical Service ambulance was on the scene, and they were just
 
         17    starting to pull away.  The area at that point was being
 
         18    cordoned off or taped off with crime scene tape.  I approached
 
         19    Sergeant Martin, who was on the scene, and requested that she
 
         20    give me a brief scenario of what she had found.
 
         21       Q.   Now, when you approached Sergeant Martin -- let me back
 
         22    up for just a minute.  In your normal course of duties as an
 
         23    evidence technician, do you have to speak to officers who are
 
         24    already on the scene once you arrive on the scene?
 
         25       A.   I prefer to do so, yes.
 
 
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          1       Q.   Would you tell the members of the jury why you do that?
 
          2       A.   I do that so that I have a reasonable understanding of
 
          3    what they know so that I know the areas to consider for evidence
 
          4    immediately.  During my search for evidence I have to prioritize
 
          5    evidence in order to collect it also so that it won't be
 
          6    trampled on, moved, or whatnot.  So in my first brief with the
 
          7    officers on the scene, I'm given an idea of particular pieces
 
          8    that I may have to address first.
 
          9       Q.   And so was that one of the reasons that you approached
 
         10    Sergeant Martin, you said?
 
         11       A.   Yes, sir.
 
         12       Q.   And when you approached her, what, if anything, did she
 
         13    say to you?
 
         14       A.   She indicated that a female was found across the street
 
         15    from where we were speaking.  When I looked across the street, I
 
         16    saw an obvious area on the side of the street, it was just in
 
         17    the grass, just off the street.  There was a large amount of
 
         18    blood.  There was --
 
         19       Q.   I'm sorry, go ahead.
 
         20       A.   There was also a spent shotgun shell casing in the
 
         21    street itself.
 
         22       Q.   And how close was the, in your estimation, was the spent
 
         23    shotgun shell casing to where you saw the bloody area in the
 
         24    grass?
 
         25       A.   It was approximately 10 feet away.
 
 
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          1       Q.   And when you first made those observations, were you
 
          2    walking from 911 Loudon Avenue, or from which direction were you
 
          3    approaching where you found the bloody grassy spots?
 
          4       A.   I approached Sergeant Martin from the 800 block of
 
          5    Loudon towards Ninth Street, 911 Loudon would have been further
 
          6    up from where I was.
 
          7       Q.   And correct me if I'm wrong, but had the victim, Robin
 
          8    Williams, had she been removed in the ambulance rescue unit that
 
          9    you described earlier?
 
         10       A.   Yes, she had.
 
         11       Q.   What did you do after you noticed the area in the grass
 
         12    and the spent shotgun casing, what did you do next?
 
         13       A.   Sergeant Martin led me from that location to the
 
         14    location of 911 Loudon avenue, where she said that some type of
 
         15    incident had occurred at that location in relation to this.
 
         16    When we arrived at that location, I found that there was an
 
         17    officer posted at a door, which I later found was a kitchen
 
         18    door.
 
         19       Q.   Let me slow you down there just a second.  When you say
 
         20    an officer posted at the door, when you say posted, what exactly
 
         21    are you referring to, what does that mean to you as an evidence
 
         22    technician?
 
         23       A.   Typically that means that there is some type of evidence
 
         24    that is being protected at that location that nobody would move
 
         25    in or out of that location.
 
 
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          1       Q.   Okay.  And where did you see officers posted when you
 
          2    went into the residence, the home there at 911 Loudon avenue?
 
          3       A.   There was an officer with the family, there was an
 
          4    officer standing outside of the kitchen doorway.
 
          5       Q.   And did you later understand that 911 Loudon was the
 
          6    home and still is the home of Mrs. Bertha Williams?
 
          7       A.   Yes, I do.
 
          8       Q.   Once you made those observations of the officers in
 
          9    those location, what did you do next?
 
         10       A.   Once I had seen the obvious evidence that was there, I
 
         11    began my phase in collection of the evidence.
 
         12       Q.   Tell the members of the jury the obvious evidence that
 
         13    you saw before you began that phase that you just described.
 
         14       A.   Okay.  The obvious pieces were of course the blood that
 
         15    I had seen up on the Ninth Street location, the spent shotgun
 
         16    shell casing in the street on Ninth Street.  Outside the kitchen
 
         17    door there were three spent shotgun shells.  On that door itself
 
         18    there were three very distinct holes around the dead bolt.
 
         19    There was patterning such as the shot debris or shot from the
 
         20    shotgun shell.  This was seen on the stove just inside the
 
         21    kitchen door, it was on the wall directly in front of the
 
         22    kitchen door; I found it on top of an ottoman or a footstool in
 
         23    the dining room; I found it on a leg of the dining room table; I
 
         24    found it on two walls of the dining room where the shot had
 
         25    scattered throughout the room.  I also located a pair of
 
 
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          1    sunglasses just inside that kitchen door.  The kitchen door
 
          2    itself, the exterior, there were smudges, dirt smudges at the
 
          3    lower portion of that door, there was a small stain of possible
 
          4    blood on the interior portion of the screen door, which was
 
          5    about two-thirds open from the kitchen door.
 
          6       Q.   Let me back you up a minute to the three holes that you
 
          7    say you observed in the side kitchen door.  Describe, if you
 
          8    would, for the jury exactly what you noticed about those holes
 
          9    and what, if anything, was significant about what you saw.
 
         10       A.   Those holes were very cylindrical.  The metal on the
 
         11    outside of the door was bent inward towards the interior portion
 
         12    of the house.  And seeing the shotgun shell casings there, a
 
         13    shotgun shell had been fired into the door, and those holes in
 
         14    and of themselves appeared that the shotgun would have been held
 
         15    very closely to that door when those rounds were fired.
 
         16       Q.   Did you take photographs of all of those items that you
 
         17    just described?
 
         18       A.   I did.
 
         19       Q.   I want to also ask you if at one point during your
 
         20    observations there and your investigation there, did you have an
 
         21    occasion to look at the phone box at the outside of Mrs.
 
         22    Williams' home there at 911 Loudon?
 
         23       A.   Yes, I did.
 
         24       Q.   What did you observe, if anything?
 
         25       A.   I found that three wires leading into the phone box
 
 
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          1    appeared to have been cut.
 
          2       Q.   And did you also at some point observe the rear gate to
 
          3    Mrs. Williams' residence?
 
          4       A.   Yes, I did.  I found that to be partially open.
 
          5       Q.   The evidence that you've described, the shotgun shells
 
          6    and the other evidence that you've described, did you collect
 
          7    that as evidence in this case?
 
          8       A.   Yes, I did.
 
          9       Q.   Would you please tell for the members of the jury in
 
         10    detail how you collected that evidence and how that is done on
 
         11    this case and in the normal course of business?
 
         12       A.   In this case, what is typically done is you photograph
 
         13    the evidence before it's ever touched.  After you take your
 
         14    photographs, both wide range and close-up photographs of this
 
         15    evidence, you move in, you examine the evidence for anything
 
         16    that maybe attached, finding nothing or documenting anything
 
         17    that is there.
 
         18            Before you move the object, you have to do measurements
 
         19    to be able to take the evidence back.  This would become an
 
         20    event where you could precisely place the evidence back where
 
         21    you collected it from.  These measurements are taken right
 
         22    before collecting that piece of evidence.  That evidence is
 
         23    collected, placed into a sealed container.  It could be a rigid
 
         24    container or a paper envelope, just depending on particular labs
 
         25    that you may submit it for later.  You seal that envelope and
 
 
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          1    initial that package as having been yours, and you submit it to
 
          2    the property room, which is a secure facility.
 
          3       Q.   And did you follow that procedure with the evidence that
 
          4    you collected at Mrs. Williams' homes as well as the evidence
 
          5    that you located out in the street?
 
          6       A.   I did.
 
          7            MR. WALKER:  May I approach the witness, Your Honor?
 
          8            THE COURT:  Yes, sir.
 
          9            BY MR. WALKER:
 
         10       Q.   Officer Sacra, I'm going to show you several items here,
 
         11    if you will bear with me as I show them to you one at a time.
 
         12    Beginning first I will show you each of the items, and then I
 
         13    will ask something about each item.
 
         14            Beginning first with Exhibit 21A, looking at that piece
 
         15    of evidence, have you ever seen that before; and if you have,
 
         16    how can you tell?
 
         17       A.   My initials are across the tape of the envelope, as well
 
         18    as it appears to be my handwriting has filled out the evidence
 
         19    portion of it.
 
         20       Q.   Is that envelope in a sealed condition at the moment?
 
         21       A.   Yes, it is.
 
         22       Q.   Okay.  Let me show you now, before I ask you again about
 
         23    that exhibit, Exhibit 21C, as well as 21E, 21G, and 21I, if you
 
         24    will take each of those one at a time and tell me if you
 
         25    recognize those items and, if so, how you recognize them?
 
 
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          1       A.   Each of these items I recognize as the envelopes I
 
          2    placed my evidence into from that same, each of these items are
 
          3    sealed, they have my initials on them, they all appear to have
 
          4    been handwritten by myself.
 
          5       Q.   And do all of the envelopes, do they appear to be in
 
          6    substantially the same condition as when you placed the items
 
          7    inside or used the envelopes and then sealed them as you
 
          8    described?
 
          9       A.   Yes, they do.
 
         10       Q.   I'm going to ask to you take these scissors, and
 
         11    beginning first with Exhibit 21A, if you would cut the top off
 
         12    of that envelope and remove the contents.
 
         13       A.   (Witness complies.)
 
         14       Q.   Referring your attention now to what you removed from
 
         15    there, and it's been previously marked as 21B, if you will take
 
         16    a look at that particular item and tell me if you have seen that
 
         17    before and, where you have seen it.
 
         18       A.   Yes, I have seen this item.  It is the dead bolt latch
 
         19    that came from the dead bolt of the kitchen door.
 
         20       Q.   Of the side of 911 Loudon?
 
         21       A.   Yes.
 
         22       Q.   Okay.  And tell the members of the jury why you
 
         23    collected that as a piece of evidence.  What was significant
 
         24    about that to you?
 
         25       A.   The significance of this, first, in seeing the three
 
 
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          1    holes in the door, I also found just inside the door, where the
 
          2    door frame itself was broken away from the wall, this indicating
 
          3    that even after three shots were fired into and around the dead
 
          4    bolt, the door never gave, and that door had to be forced open
 
          5    even after being shot three times.  This was found laying in the
 
          6    floor broken off as the door frame broke and this broke out of
 
          7    the dead bolt.
 
          8       Q.   That's why you collected that as a piece of evidence?
 
          9       A.   Yes, it is.
 
         10       Q.   Is it in the same condition as you when you collected
 
         11    it?
 
         12       A.   Yes, it is.
 
         13            MR. WALKER:  Your Honor, I would move Exhibit 21A, the
 
         14    envelope and its contents, and Exhibit 21B, the dead bolt lock,
 
         15    into evidence.
 
         16            THE COURT:  Let it be admitted.
 
         17            BY MR. WALKER:
 
         18       Q.   Referring your attention now, sir, to Exhibit 21C, that
 
         19    envelope that you testified about, will you cut the top off of
 
         20    that and remove the contents?
 
         21       A.   (Witness complies.)
 
         22       Q.   And you have removed an item that is marked as
 
         23    Government's Exhibit 21D, if you will take a look at that item
 
         24    and tell us if you recognize what that is.
 
         25       A.   I do.
 
 
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          1       Q.   What is that?
 
          2       A.   This is the spent shotgun shell that I located on 9th
 
          3    Street at the intersection of Ninth and Loudon.
 
          4       Q.   Is it in substantially the same condition as when you
 
          5    collected it at that location?
 
          6       A.   Yes, it is.
 
          7            MR. WALKER:  Your Honor, I would move admission of the
 
          8    envelope first, 21C, and the shotgun shell, 21D.
 
          9            THE COURT:  Let it be admitted.
 
         10            BY MR. WALKER:
 
         11       Q.   Referring your attention now to Government's Exhibit
 
         12    21E, this evidence envelope, if you will use those scissors on
 
         13    that and remove the contents.
 
         14       A.   (Witness complies.)
 
         15       Q.   And you have removed an item which is marked as
 
         16    Government's Exhibit 21F.  Tell us if and where you have seen
 
         17    that item before.
 
         18       A.   This item is the spent shotgun shell that I located on
 
         19    the steps to the kitchen doorway into 911 Loudon.
 
         20       Q.   And is it also in substantially the same condition now
 
         21    as when you found it --
 
         22       A.   Yes, sir, it is.
 
         23       Q.   -- outside of Mrs. Williams' home?
 
         24       A.   Yes.
 
         25            MR. WALKER:  I would move, Your Honor, the evidence
 
 
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          1    envelope, 21E, and the contents, the shotgun shell casing, 21F,
 
          2    into evidence.
 
          3            THE COURT:  Let it be admitted.
 
          4            BY MR. WALKER:
 
          5       Q.   Turning your attention now to Government's Exhibit 21G,
 
          6    if you will unseal that and remove the contents.
 
          7       A.   (Witness complies.)
 
          8       Q.   You have removed an item which is labeled 21H, and you
 
          9    removed that from that envelope, 21G.  Have you ever seen 21H
 
         10    before?
 
         11       A.   Yes, I have.
 
         12       Q.   How can you tell that you have seen 21H?
 
         13       A.   I've initialed each of these upon the collection to
 
         14    refer back.
 
         15       Q.   And when you say you initialed each of these, you are
 
         16    referring to each of the shotgun shells that you removed from
 
         17    these envelopes?
 
         18       A.   All of them had my initials on them.
 
         19       Q.   Okay.  And 21H, where did you locate that item?
 
         20       A.   This is the spent shotgun shell that -- there were two
 
         21    shotgun shell casings beside a trash bag just off from the
 
         22    kitchen doorway, and beside that there was the closest one,
 
         23    which was this one, and then one further away, which I
 
         24    collected.
 
         25       Q.   And is that item as well in the same condition as when
 
 
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          1    you collected it?
 
          2       A.   Yes, it is.
 
          3            MR. WALKER:  Your Honor I would move the evidence
 
          4    envelope, 21G, and the contents, the shell, 21H, into evidence.
 
          5            THE COURT:  Let it be admitted.
 
          6            BY MR. WALKER:
 
          7       Q.   Lastly, let me turn your attention to the envelope, 21I,
 
          8    if would unseal that envelope and remove the contents.
 
          9       A.   (Witness complies.)
 
         10       Q.   You have removed an item, and how is that particular
 
         11    item marked?
 
         12       A.   It's 21J.
 
         13       Q.   Referring your attention then to Government's Exhibit
 
         14    21J, have you ever seen that item?
 
         15       A.   Yes, I have.
 
         16       Q.   Does it also bear your initials?
 
         17       A.   It bears my initials.
 
         18       Q.   Where did you locate that item?
 
         19       A.   This was the second shotgun shell spent casing that was
 
         20    located beside the trash bag furthest from the door.
 
         21       Q.   Is it in the same condition as when you collected it?
 
         22       A.   It is.
 
         23            MR. WALKER:  Your Honor, I would move 21I and 21J into
 
         24    evidence.
 
         25            THE COURT:  Let them be admitted.
 
 
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          1            BY MR. WALKER:
 
          2       Q.   Did you also complete two diagrams of the area of that
 
          3    block of Loudon Avenue as well as the inside of 911 Loudon
 
          4    Avenue?
 
          5       A.   Yes, I did.
 
          6            MR. WALKER:  May I approach the witness, Your Honor?
 
          7            THE COURT:  Yes, sir.
 
          8            BY MR. WALKER:
 
          9       Q.   I'm going to show you Government's Exhibit 21K and 21L,
 
         10    and I will ask you, looking first at Government's Exhibit 21K,
 
         11    have you ever seen that item before?
 
         12       A.   Yes, I have.
 
         13       Q.   Is that the diagram that you drew of the inside of Mrs.
 
         14    Williams' homes there at 911 Loudon Avenue?
 
         15       A.   It is.
 
         16       Q.   And you have some markings on your diagram.  Describe
 
         17    what -- you have a legend there?
 
         18       A.   Yes.  The legend indicates different points of evidence
 
         19    that I located that were different items within the room.
 
         20       Q.   And I will also show you Government's Exhibit 21L.  Is
 
         21    that the second diagram that you drafted in this case?
 
         22       A.   It is.
 
         23       Q.   And does it show the intersection of Ninth and Loudon
 
         24    Avenue?
 
         25       A.   Yes, it does.
 
 
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          1       Q.   Including the home, 911 Loudon Avenue?
 
          2       A.   Yes.
 
          3            MR. WALKER:  Your Honor, I would move admission of 21K
 
          4    and 21L.
 
          5            THE COURT:  Let them be admitted.
 
          6            BY MR. WALKER:
 
          7       Q.   And let me also show you, Officer Sacra, referring your
 
          8    attention first to Government's Exhibit 21M, does this appear to
 
          9    be an enlarged edition of the diagram we just introduced?
 
         10       A.   It does.
 
         11       Q.   And again looking at this diagram as well, Government's
 
         12    Exhibit 21N, does it also appear just to be an enlarged diagram
 
         13    of the smaller diagrams that you drew?
 
         14       A.   Yes, sir.
 
         15       Q.   And would these enlarged diagrams help you illustrate
 
         16    exactly where you located these evidence items that you
 
         17    testified about?
 
         18       A.   Yes, they would.
 
         19            MR. WALKER:  Your Honor, may he join me down in front of
 
         20    the jury?
 
         21            THE COURT:  Yes, sir.
 
         22            MR. WALKER:  If you would come down, please, sir.
 
         23            THE COURT:  21N, did you want to move admission --
 
         24            MR. WALKER:  Your Honor, I would move admission of 21N
 
         25    and 21M.
 
 
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          1            THE COURT:  Let them be admitted.
 
          2            BY MR. WALKER:
 
          3       Q.   Turning your attention first, Officer Sacra, and I'm
 
          4    going to first ask all of the members of the jury if they can
 
          5    see this diagram where it's situated?
 
          6            (Jurors nod heads.)
 
          7            BY MR. WALKER;.
 
          8       Q.   Now, if you can, using that pointer, describe the item
 
          9    that you located and the -- where you described the blood on the
 
         10    grass when you arrived there at Loudon.
 
         11       A.   Myself and Sergeant Martin were standing at this
 
         12    location here, I found the blood to be in the grass just off the
 
         13    pavement at this location, approximately 10 feet away from the
 
         14    blood I found the spent shotgun shell casing on the street.
 
         15       Q.   Now let me also refer your attention to bottom of this
 
         16    diagram.  You have done a legend, is that correct?
 
         17       A.   Yes.
 
         18       Q.   Would you please explain each of the items, and I'm
 
         19    going to hold that up so that the jury can read that, each of
 
         20    the items that you indicated on your legend.
 
         21       A.   A is the spent shotgun shell casing located on the
 
         22    street.  B is the blood that I located in the grassy area of
 
         23    beside the street.  C is the telephone access -- I'm sorry,
 
         24    telephone access covers.  These were placed on the diagram to
 
         25    indicate where I took my measurements from.  D is the gate at
 
 
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          1    the rear fence of 911 Loudon Avenue.  E is the east side kitchen
 
          2    door where the three shotgun, spent shotgun shell casings were
 
          3    found.  F is the residential telephone box.  This was on the
 
          4    back wall of the residence.  G was the fence around the
 
          5    residence itself, which encompassed all of this area.  H
 
          6    indicates sidewalks on both sides of Loudon Avenue.
 
          7       Q.   Okay.  Let me ask you one more question.  You indicated
 
          8    that you used -- you put something on your legend to indicate
 
          9    distance.  Explain that to the jury.  What measuring point did
 
         10    you mean by that?
 
         11       A.   When we take measurements, we have to take measurements
 
         12    from certain points that we can return to at some point and
 
         13    replace the evidence where we located it.  We look for permanent
 
         14    objects to which we can go back to, something that's not going
 
         15    to be moved by weather or by normal maintenance.  These are two
 
         16    telephone access covers.  These are like manhole covers that
 
         17    were located on this upper level of grassy area.  These are
 
         18    where I triangulated both points A and B when taking my
 
         19    measurements.
 
         20       Q.   Okay.  And I'm going to take this diagram down and
 
         21    replace it with the other enlarged diagram, that being
 
         22    Government's Exhibit 21M, and I will also hold this up for all
 
         23    of the members of the jury to be able to read your legend here.
 
         24    Would you indicate what you indicated on your legend and what
 
         25    that signifies to you?
 
 
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          1       A.   A was the sunglasses that I located against the short
 
          2    wall that separates the kitchen and the dining room, it was on
 
          3    the interior of the house.
 
          4            B is the shot damage, shotgun pellets that went through
 
          5    the house.  Anything that I found damage on I indicated here.  I
 
          6    found shot damage to the side of the stove; I found it on
 
          7    the -- this short wall; I found it on, this was a footstool or
 
          8    ottoman; I found shot damage on the leg to the dining room
 
          9    table; I found shot damage to the drapes on this window, shot
 
         10    damage also to this small wall here.
 
         11            C was the east side doorway and door that had the three
 
         12    distinct cylindrical holes around the dead bolt.  I had taken
 
         13    wood samples from that as well as selected some wood samples
 
         14    throughout these rooms to be sure that they came back from that
 
         15    door.
 
         16            D was where I located the item I removed from the
 
         17    evidence package, which was the dead bolt latch.
 
         18            E was where I located some of the wood that I collected
 
         19    to compare back to the door.
 
         20            F is a blood swab and a control swab that I had taken
 
         21    from the interior surface of the screen door cover in the
 
         22    kitchen door.
 
         23            G are spent federal shotgun shell casings located here
 
         24    on the steps just outside, and then the other two which were
 
         25    beside the trash bag.
 
 
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          1            H indicates the ottoman which I found shot damage to.
 
          2            I were more wood chips located just inside that door.
 
          3       Q.   You may take your seat.
 
          4            You indicated as part of your duties as a crime scene
 
          5    technician that you take photographs.  Did you do that in this
 
          6    case?
 
          7       A.   I did.
 
          8            MR. WALKER:  May I approach the witness, Your Honor?
 
          9            THE COURT:  Yes, sir.
 
         10            BY MR. WALKER:
 
         11       Q.   First of all I want to show you, beginning with
 
         12    Government's Exhibit S -- 21S, excuse me, Government's Exhibit
 
         13    21S, and I'm going to name these off and then I'll hand them to
 
         14    you, if that's okay.  21S, 21T, 21U, 21V, 21W, 21Y, 21Z, and
 
         15    21X, 21AA, 21BB, 21CC, 21DD, 21FF, 21GG, 21HH, 21II, 21JJ, 21KK,
 
         16    21LL, and, lastly, 21MM.  If you will take each one of those
 
         17    photographs that I've handed you and indicate if you are the
 
         18    person who took those photographs.
 
         19       A.   I am.
 
         20       Q.   And after you've looked at each of those, do each of
 
         21    those photographs fairly and accurately show the outside of 911
 
         22    Loudon and the contents that you collected from the outside as
 
         23    well as the inside and the contents you collected from the
 
         24    inside as you found them when you responded to that call that
 
         25    morning?
 
 
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          1       A.   Yes, they do.
 
          2            MR. WALKER:  Your Honor, I would move all of those
 
          3    exhibits into evidence, those photographs.
 
          4            THE COURT:  There's a number of them, let's just run
 
          5    down them one more time.
 
          6            MR. WALKER:  Your Honor, that would begin with 21S.
 
          7            THE COURT:  21S, going through --
 
          8            MR. WALKER:  It would be 21S through Z, and then
 
          9    beginning again, Your Honor, with 21AA, proceeding through 21MM.
 
         10            THE COURT:  They will be admitted.
 
         11            MR. WALKER:  Your Honor, may he join me in front of the
 
         12    jury?
 
         13            THE COURT:  Yes, sir.
 
         14            BY MR. WALKER:
 
         15       Q.   Officer Sacra, if you would come down again and,
 
         16    beginning with this side of the jury, using these photographs
 
         17    pick them up one at a time and indicate by pointing on the
 
         18    photograph why you took that particular picture.
 
         19       A.   This is a mid range photography shot of the telephone
 
         20    access box that was attached to the rear of 911 Loudon Avenue.
 
         21       Q.   Okay.  And if you would, go down to that side of the
 
         22    jury and do the same because they may have had trouble seeing or
 
         23    hearing what you said.
 
         24       A.   This is the telephone access box that is attached to the
 
         25    rear of 911 Loudon Avenue, it's a mid range shot.  We do three
 
 
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          1    different types of shots when we collect evidence.  We typically
 
          2    take a wide range, a mid range, and a closeup of the evidence
 
          3    itself.
 
          4       Q.   And referring then to 21T.
 
          5       A.   21T, it's a little dark.  What this is is a close-up
 
          6    shot of the wires that had been cut leading to that box we saw
 
          7    in the last photograph.
 
          8            THE COURT:  Don't forget these two jurors down at the
 
          9    end.
 
         10            THE WITNESS:  One end that you can distinctly see would
 
         11    be right here that had been cut.
 
         12            BY MR. WALKER:
 
         13       Q.   Okay.  And referring then to 21U, if you would do the
 
         14    same with that photograph.
 
         15       A.   21U is a photograph that was taken from the interior
 
         16    side of the kitchen door.  You can see the damage along the
 
         17    edges of the dead bolt lock, so this would be where the shot
 
         18    came through the door, this is the interior side of the kitchen
 
         19    door, the damage being around the dead bolt.
 
         20       Q.   I'll ask you, before you look at 21V, you indicated you
 
         21    also took photographs of the damage to the dead bolt on the
 
         22    outside?
 
         23       A.   Yes, I did.
 
         24       Q.   Is that what is shown in 21V?
 
         25       A.   That is correct.
 
 
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          1       Q.   If you would indicate to the jury what you saw.
 
          2       A.   In this photograph you can see what I was describing
 
          3    earlier, very cylindrical holes with the metal from the outside
 
          4    of the door moving inward towards the inner core of the door.
 
          5    This photograph was taken from the exterior of the kitchen
 
          6    door.
 
          7       Q.   And there is no -- correct me if I'm wrong, but is there
 
          8    any pellet damage other than around any of cylinder holes that
 
          9    you described?
 
         10       A.   I found no pellet damage on the exterior part of that
 
         11    door.
 
         12       Q.   Why was that significant to you?
 
         13       A.   That would indicate that the shotgun itself would have
 
         14    been held very closely, if not right onto the door when it was
 
         15    fired.
 
         16       Q.   And looking at 21U, -- I'm sorry, I believe I have
 
         17    already shown you that one.  21W.
 
         18       A.   21W is a mid range shot taking in the door and the
 
         19    shotgun shell spent casings that were located around the door,
 
         20    and in this shot itself the casings may not be very distinct,
 
         21    but that's why we take a close-up.  This is the kitchen door
 
         22    itself.  The shotgun shell casings would have been in the steps
 
         23    in the trash bag area of this photograph.
 
         24       Q.   I will hand you 21X, if you will do the same with that
 
         25    photograph.
 
 
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          1       A.   21X is the three shotgun shell casings, spent casings
 
          2    that were located outside the residence, one on the steps and
 
          3    two by the trash bag.  The spent casings, there is one on the
 
          4    steps and two beside the trash bag.  This is the one on the
 
          5    steps and two beside the trash bag.
 
          6       Q.   And the trash bags that you described, are they shown in
 
          7    the picture that you previously indicated, 21W, are they seen
 
          8    there in that photograph?
 
          9       A.   The trash bags right here.
 
         10       Q.   And that's the same trash bag that you showed from a
 
         11    close-up shot in 21X?
 
         12       A.   It is.
 
         13       Q.   Referring to 21Y.
 
         14       A.   21Y is a mid range shot of the interior of the kitchen
 
         15    door.  If you look at this photograph, you will see the damage
 
         16    to the wood trim that was holding the latch to the dead bolt in
 
         17    place, and you can see that it's damaged, pulled away from the
 
         18    wall.  You can see the damage to the interior portion of the
 
         19    door where the shot traveled through the door, the door frame
 
         20    itself being pulled away from the wall towards the bottom, the
 
         21    damage to the interior portion of the kitchen door. .
 
         22       Q.   And again with 21Z.
 
         23       A.   21Z would be taken just inside that kitchen doorway.
 
         24    This is the side of the stove that was just inside that door.
 
         25    You can see the small marks and pits in the side of the stove,
 
 
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          1    and this is what I indicated is shot damage, that had glanced
 
          2    off of the side of that stove.
 
          3       Q.   As well as 21AA.
 
          4       A.   21AA is the small inner wall that separates the kitchen
 
          5    from the dining room and the shot damage located right on its
 
          6    corner.
 
          7       Q.   If you would do the same thing with the other
 
          8    photographs, beginning with 21BB.
 
          9       A.   21BB shows debris, the interior of the kitchen door
 
         10    being up here.  Along the floor you will see wood chips laying
 
         11    along the floor.  And this is debris that carried from that
 
         12    interior side of the door across to the dining room.  I was
 
         13    standing in the dining room when I took this photograph.
 
         14            21CC indicates a close-up that I took of the area around
 
         15    the interior side of the kitchen door.
 
         16       Q.   There is also another item in that photograph.  Is that
 
         17    a -- what is that item placed in the photograph for?
 
         18       A.   The scale?
 
         19       Q.   Right.
 
         20       A.   The scale is placed in the close-up diagrams so that you
 
         21    know the approximate size of what you are working with, and it
 
         22    also gives the ability to check these photographs to see if
 
         23    possibly they have been altered.
 
         24            This shows the damage around the dead bolt lock,
 
         25    interior side of the kitchen door.
 
 
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          1       Q.   21CC?
 
          2       A.   21CC is also a close-up.  It is the shot damage on the
 
          3    short wall separating the kitchen and dining room.  This is the
 
          4    same as a picture you saw earlier, only this one has the scale
 
          5    in it.
 
          6            21DD indicates the damage to the dining room chair, the
 
          7    dining room table leg.  This would be another table leg, the
 
          8    further side of the room.  If you see the small white specs in
 
          9    the photograph and the wood chips along the floor, this is
 
         10    damage away from the actual door itself in the dining room.
 
         11            THE COURT:  Officer Sacra, if you would, be sure these
 
         12    two jurors on the end see it.
 
         13            THE WITNESS:  Oh, I'm sorry.
 
         14            BY MR. WALKER:
 
         15       Q.   Referring your attention then, skipping over 21EE,
 
         16    looking at 21FF.
 
         17       A.   21FF indicates the shotgun shell which was closest to
 
         18    the kitchen door next to the trash bag.  There were three
 
         19    shotgun shells, one on the steps; there was a second, which was
 
         20    this one, which is closest to the door; and a third which was
 
         21    laying right directly beside the trash bag, which was furthest
 
         22    away.  This would be the second.  It has the scale in it, and
 
         23    again, indicating a close-up view of the spent shotgun shell.
 
         24       Q.   Looking at 21GG.
 
         25       A.   21GG would be the third shotgun shell, or the one
 
 
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          1    furthest away from the kitchen door, laying directly beside the
 
          2    trash bag.
 
          3       Q.   And 21HH?
 
          4       A.   21HH is indicating the shotgun shell that was located on
 
          5    the steps itself, closest to the kitchen door.
 
          6       Q.   And 21II?
 
          7       A.   21II indicates the spent shotgun shell that I located on
 
          8    9th Street approximately 10 feet away from the stain in the
 
          9    grass.
 
         10       Q.   And I'm going to give you now 21LL.  Using 21LL would
 
         11    you indicate what that is a photograph of?
 
         12       A.   21LL is a photograph of the alleyway behind the
 
         13    residence.
 
         14       Q.   And when you say residence, are you referring to Ms.
 
         15    Williams' residence at 911 Loudon?
 
         16       A.   Yes, I am.
 
         17       Q.   And before I show you 21JJ I want to turn your attention
 
         18    very briefly again to your diagram.  Let me retrieve that.
 
         19            The alleyway that you just described in the photograph
 
         20    that you just presented to the jury, point out on the diagram
 
         21    where that alleyway is, this being -- what I'm pointing to is
 
         22    911 Loudon Avenue, is that correct?
 
         23       A.   Yes, it is.
 
         24       Q.   If you would describe where the alleyway is.
 
         25       A.   The alleyway runs from Ninth Street behind the residence
 
 
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          1    and dead ends up towards Tenth Street.
 
          2            THE COURT:  Can you folks see that?
 
          3            (Jurors shake heads.)
 
          4            THE COURT:  Mr. Walker, be sure those jurors can see.
 
          5            THE WITNESS:  Yes, sir, I have that marked on the
 
          6    diagram as the alleyway.
 
          7            BY MR. WALKER:
 
          8       Q.   And you said -- correct me if I'm wrong, but you said it
 
          9    dead ends up towards me?
 
         10       A.   Yes.
 
         11       Q.   And it intersects the alleyway, doesn't it, Loudon
 
         12    intersects the alleyway?
 
         13       A.   Ninth Street.
 
         14       Q.   I'm sorry, Ninth Street.
 
         15       A.   Yes, sir.
 
         16       Q.   Okay.  And referring your attention back to just two of
 
         17    the photographs that are all in the evidence, 21JJ, indicate
 
         18    what that signifies to you.
 
         19       A.   21JJ is the shotgun, spent shotgun shell that I located
 
         20    on Ninth Street approximately 10 feet from the blood in the
 
         21    grass.
 
         22       Q.   Officer Sacra, the four shotgun shells that you have
 
         23    shown the jury in these photographs, those are the four shells
 
         24    that you removed from those evidence envelopes, is that correct?
 
         25       A.   Yes, they were.
 
 
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          1       Q.   Lastly, showing you 21EE, using that photograph --
 
          2       A.   21EE is the blood stain that was located in the grass
 
          3    adjacent to 9th Street where I was advised that the victim had
 
          4    been found.
 
          5            MR. WALKER:  You may return to the witness stand,
 
          6    Officer Sacra.
 
          7            I think, Your Honor, I don't have any other questions of
 
          8    this officer.
 
          9            THE COURT:  All right, sir.  Cross?
 
         10            MR. WILLIAMS:  No questions, Your Honor.
 
         11            THE COURT:  Thank you, sir.  You may step down.
 
         12            Call your next witness.
 
         13            MR. CONRAD:  The United States would call Bertha
 
         14    Williams.
 
         15                       BERTHA LUCILLE WILLIAMS,
 
         16    being first duly sworn, was examined and testified as follows:
 
         17                         DIRECT EXAMINATION
 
         18            BY MR. CONRAD:
 
         19       Q.   Would you tell the jury your name?
 
         20       A.   My name is Bertha Lucile Williams.
 
         21       Q.   Mrs. Williams, as best you can, go ahead and speak up.
 
         22       A.   All right.
 
         23       Q.   You are the mother of Robin Williams, are you not?
 
         24       A.   Yes, I am.
 
         25       Q.   How old was Robin when she died?
 
 
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          1       A.   She was 23.
 
          2       Q.   Ms. Williams, let me approach and hand to you what has
 
          3    been marked for identification as Government's Exhibit 22 and
 
          4    ask you, can you identify that for me, please.
 
          5       A.   That's my daughter.
 
          6       Q.   That's your Robin?
 
          7       A.   That's my Robin.
 
          8            MR. CONRAD:  Move admission.
 
          9            THE COURT:  22 will be admitted.
 
         10            MR. CONRAD:  Request permission to pass this picture to
 
         11    the jury.
 
         12            THE COURT:  Yes, sir.
 
         13            BY MR. CONRAD:
 
         14       Q.   Ms. Williams, I know there are a lot of things that you
 
         15    would like to tell this jury about your daughter, Robin, but I
 
         16    want to direct your attention to her relationship with Mark
 
         17    Barnette, do you understand?
 
         18       A.   I understand.
 
         19       Q.   Do you see Mr. Barnette in the courtroom today?
 
         20       A.   Yes, I do.
 
         21       Q.   Would you please point to him, describe what he is
 
         22    wearing?
 
         23       A.   He is sitting in between the lawyers here.  He has got
 
         24    on a navy blue jacket with gray pants.
 
         25       Q.   And you have met him before?
 
 
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          1       A.   Yes.
 
          2       Q.   When was the first time that you had ever met him?
 
          3       A.   In the spring, I think of '94.
 
          4       Q.   And go ahead and tell the jury how it came about that
 
          5    you had met him.
 
          6       A.   He came up one Sunday -- well, he came up -- Robin had
 
          7    met him at a club.  She told me that she had met this fellow and
 
          8    she said, mom, he is going to call me today, and I said okay.
 
          9       Q.   Now, did she tell you that the day after she met him?
 
         10       A.   That was the day after she met him.  She met him on
 
         11    Saturday night.
 
         12       Q.   And at the time that she had met him, was she living
 
         13    with you?
 
         14       A.   Yes.  She had never been away from home.
 
         15       Q.   Tell the jury about your relationship with your
 
         16    daughter.
 
         17       A.   Well, she was my baby, my only little girl.
 
         18       Q.   And did she stay with you at your house?
 
         19       A.   She stayed with me.  She had never been away from home.
 
         20    She was even in my bed before she left.  She had her own bed,
 
         21    but she slept with her mommy.  She called me mommy all of her
 
         22    life.
 
         23       Q.   Now, on that Sunday that she told you the defendant
 
         24    would call her, did you ever met him on that day?
 
         25       A.   I didn't meet him that day.  He called and I answered
 
 
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          1    the phone.  And I had to go to church; and while I was at
 
          2    church, she talked to him and she had went to where he was, to
 
          3    Greg's house, or somebody's house, and got him and they had come
 
          4    back to my house, but I wasn't there.
 
          5       Q.   Sometime shortly thereafter did you meet him?
 
          6       A.   I did.  He came up and he went to church with her.
 
          7       Q.   Did you go to church with the two of them?
 
          8       A.   Well, I was already at church when they came, because
 
          9    I'm Sunday school superintendent.
 
         10       Q.   Is that the first place that you ever met the defendant?
 
         11       A.   That's when I first met him.
 
         12       Q.   At church?
 
         13       A.   At church.
 
         14       Q.   Now, from that point of time forward, describe the
 
         15    relationship your daughter Robin had with the defendant.
 
         16       A.   Well, she and Mark dated long distance, they would call
 
         17    each other, she would call him and he would call her, and
 
         18    sometimes her telephone would be bill would be $200 a month, she
 
         19    paid it because she worked diligently.  On occasions he would
 
         20    come up, but then sometimes she would drive to Charlotte.
 
         21       Q.   Did you welcome him into your house?
 
         22       A.   Yes, I did.
 
         23       Q.   Why did you do that?
 
         24       A.   Because of Robin, she liked him.  As a matter of fact,
 
         25    she actually loved this boy, she thought the world of this boy.
 
 
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          1       Q.   Did there come a time when she left your house and moved
 
          2    in on her own?
 
          3       A.   Yes.
 
          4       Q.   When did that happen?
 
          5       A.   They had been dating about a year long distance, and she
 
          6    said mama, I'm going to get me an apartment.  And I said why?
 
          7    And she said well, I'm just going to move out and Mark is going
 
          8    to come up here.  The first they had decided to move to
 
          9    Charlotte, but she was talking around and she spoke to her
 
         10    brothers and they said no.  They said if you are going to move
 
         11    in with this boy, he comes here, you don't go to Charlotte.  She
 
         12    said that she told Mark this, so they decided to come to
 
         13    Roanoke.
 
         14            And she and I were out one day, and I said -- we were
 
         15    talking about her moving out, and I said, well don't do it yet,
 
         16    Robin, you know, it will be a lot more fun to live by yourself,
 
         17    and you can go and come as you please.  She said no, mom but I
 
         18    love Mark, and I want to be with Mark.  And I said okay, but I
 
         19    said I don't want you to move out, I want you to wait awhile.
 
         20    And she said, mom, I can't stay home forever.  So I let it
 
         21    alone.  She was 21, I couldn't make her stay home after 21.
 
         22       Q.   Did she move out of your house, do you know when?
 
         23       A.   She moved out of my house in March.
 
         24       Q.   Of 95?
 
         25       A.   '95.
 
 
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          1       Q.   Now, you've been here for the whole trial, have you not?
 
          2       A.   Yes.
 
          3       Q.   And you heard the previous testimony, did you hear
 
          4    testimony about an incident in June of 1995 when the police were
 
          5    called to Robin's apartment?
 
          6       A.   I heard that.
 
          7       Q.   And what if anything do you know about that incident?
 
          8       A.   I know nothing about that.
 
          9       Q.   Did there come a time when you learned that things were
 
         10    not going as well as they had originally gone between your
 
         11    daughter and the defendant?
 
         12       A.   I think Mark had been -- I think he had been in Roanoke
 
         13    maybe three, four months, and she knew she didn't want to live
 
         14    with him anymore.  She said, what do I do mama?  She said, I'm
 
         15    not happy.  And I said well, just go downtown and tell him that
 
         16    you're living with somebody and you don't want to live with them
 
         17    anymore.  And she did, and they told her the procedures, and she
 
         18    he wrote him a 30-day notice.  When she gave I to him, he
 
         19    promised her he was going to be better.  And she believed him
 
         20    and things were fine for a couple of months, and it went sour
 
         21    again.  He had her to the place where if she didn't come home,
 
         22    if she wasn't home two or three hours he was calling to see
 
         23    where she was, she couldn't go out with her friends.  If she was
 
         24    with me on Saturdays to the store, she couldn't stay long, she
 
         25    had to get back.  She would come home -- after she was home, she
 
 
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          1    would have to call back to let him know that she was still at
 
          2    mama's.
 
          3       Q.   Did she from time to time stop living at the apartment
 
          4    at Keswick and come live with you?
 
          5       A.   Several times, several times I'd look up and she would
 
          6    come in, and I'd say what are you doing home?  And she would
 
          7    say, I'm going to stay with you mama.  And she would stay with
 
          8    me two or three days.
 
          9       Q.   Did she tell you why?
 
         10       A.   No.  I knew things wasn't right there, and she would
 
         11    come over and say I don't know what is wrong with Mark, and she
 
         12    would stay home two or three days, put her cold feet on me, keep
 
         13    me warm mommy.  And she'd get up in the morning and say oh, I
 
         14    slept so good.  She would come home sometimes in the afternoon
 
         15    at 4:30 and she would get on the sofa and go to sleep.  I
 
         16    was -- I always wondered why you come home to see me and go to
 
         17    sleep.  She just laughed because she was always smiling and
 
         18    never complaining.
 
         19            MR. WILLIAMS:  Judge, Your Honor, please, respectfully,
 
         20    I apologize for the interruption.  For the record I would
 
         21    respectfully object to hearsay testimony, and if we could have a
 
         22    standing objection I would appreciate it.
 
         23            THE COURT:  We will have to take each question as it
 
         24    comes.
 
         25            MR. WILLIAMS:  I didn't want to interrupt her every
 
 
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          1    time.
 
          2            THE COURT:  Thank you.
 
          3            BY MR. CONRAD:
 
          4       Q.   Ms. Williams, you were here for the opening statement,
 
          5    were you not?
 
          6       A.   Yes.
 
          7       Q.   Did you hear the defense attorney talk about after your
 
          8    daughter was killed that his client attempted to commit suicide?
 
          9       A.   Yes.
 
         10       Q.   Did you hear that?
 
         11       A.   Yes.
 
         12       Q.   In the year and a half before your daughter's death that
 
         13    you were aware of her relationship with Mr. Barnette, did he
 
         14    ever attempt to commit suicide to your knowledge, or did he ever
 
         15    indicate that he was going to do that to your knowledge?
 
         16       A.   All the time.
 
         17       Q.   All the time?
 
         18       A.   He was always complaining about committing suicide, I
 
         19    even saw him standing in the bathroom window at the apartment
 
         20    one night threatening to jump out.
 
         21       Q.   Go ahead and tell me about that?
 
         22       A.   He had been down here to North Carolina for a couple of
 
         23    weeks, and he had come back, and I guess he had been back about
 
         24    a week and I got a telephone call late at night from Granny.
 
         25    And I went down there, and while I was standing outside with
 
 
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          1    Granny, she said Mark had been fighting her.  I walked in the
 
          2    house, and he was standing out the door, and I pushed him up
 
          3    against the wall and I said why are you hitting her?  I said, I
 
          4    told her not to come back and get you, and she said -- he said
 
          5    oh, you told her not to come get me?  And I said yes, I did
 
          6    because she is not happy.  I waited until she packed her clothes
 
          7    and I went and got in my car, she got in her car, I pulled off
 
          8    and he was standing outside telling her he was going to kill
 
          9    himself.
 
         10            I pulled off, she pulled off, I got half a block away
 
         11    and I looked back and I didn't see Robin.  So I went back and
 
         12    she was sitting looking up at the apartment.  I stopped and I
 
         13    looked up, and he was standing up in the window this way in the
 
         14    bathroom window, and I said Robin come on, come on, let's go
 
         15    home.  And she came home with me.  The phone range about 2:00
 
         16    and he told her if she didn't come back he wouldn't be there in
 
         17    the morning.  And I said let's go to bed.  And she said no mama,
 
         18    and I said let's go to bed, he is not going to do that.  7:00
 
         19    the next morning the phone rung and it was Mark.
 
         20       Q.   Let me jump forward just briefly to a time that you were
 
         21    with her at UVA hospital.
 
         22       A.   Yes.
 
         23       Q.   After the fire bombing.
 
         24       A.   Yes.
 
         25       Q.   Did she indicate to you at that point any concerns she
 
 
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          1    had about the defendant?
 
          2       A.   Well, she told me, she said --
 
          3            MR. LAUGHRUN:  Objection.
 
          4            THE WITNESS:  Well --
 
          5            MR. LAUGHRUN:  Objection.
 
          6            MR. CONRAD:  I will withdraw the question judge.
 
          7            BY MR. CONRAD:
 
          8       Q.   Do you know whether Robin ever called the defendant's
 
          9    mother with respect to getting him out of her apartment?
 
         10       A.   Yes.
 
         11       Q.   What do you know about that?
 
         12       A.   I know she called her three times.
 
         13       Q.   And was --
 
         14       A.   One time in particular she called her, and I was
 
         15    standing -- well, two times I know she called her, the last time
 
         16    she called Robin she told Robin, well, he is just like his daddy
 
         17    and y'all just need to talk --
 
         18            MR. WILLIAMS:  Objection.
 
         19            THE COURT:  Wait a minute, sustained.
 
         20            MR. CONRAD:  Judge, can I try to ask it in a way that
 
         21    would avoid objection?
 
         22            THE COURT:  Yes, sir.
 
         23            BY MR. CONRAD:
 
         24       Q.   You were there present on a couple of occasion?
 
         25       A.   I was will.
 
 
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          1       Q.   And you heard Robin's end of the conversation but not
 
          2    the other end?
 
          3       A.   No, that's right.
 
          4       Q.   Did Robin ever -- strike that.  Did you -- can I turn
 
          5    your attention to the week of April 10th of 1996 and ask you
 
          6    whether anything about that week stands out in your mind?
 
          7       A.   I think that's the night Robin and Mark finally broke
 
          8    up.
 
          9       Q.   Go ahead and tell the jury what you know about that
 
         10    night?
 
         11       A.   Robin had talked to me around 5:00 in the afternoon, and
 
         12    she told me that she was going to tell Mark again that she
 
         13    couldn't live with him.  And she called me up about 11:00 that
 
         14    night, and she said Mommy, I told Mark that I couldn't live with
 
         15    him again.  And I said what did he say?  And she said nothing.
 
         16    I got a call about 1:30, 2:00 in the morning, and the phone
 
         17    rang.  By the time I turned over to answer it it quit.  Someone
 
         18    said you better see who that is this time of night, and I just
 
         19    pushed star 69 and it was somebody else on the line, and she was
 
         20    saying your daughter, your daughter.  And I said what are you
 
         21    talking about, and she said --
 
         22            MR. WILLIAMS:  Objection.
 
         23            THE COURT:  Sustain the objection.
 
         24            THE COURT:  If you speak up when you have an objection,
 
         25    I have to watch you to see what you are doing over there.
 
 
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          1            BY MR. CONRAD:
 
          2       Q.   You pushed star 69, you talked to someone and then what
 
          3    did you do?
 
          4       A.   I had to get up and go, the apartment was on fire.  I
 
          5    got up and woke my brother, I said come on, go with me Robin's
 
          6    apartment is on fire.
 
          7       Q.   Ms. Williams, that is April 30th, that's the fire
 
          8    bombing, I want to draw your attention --
 
          9       A.   I apologize, I'm just --
 
         10       Q.   That's okay, I want to draw your attention to a couple
 
         11    of weeks before this?
 
         12       A.   This was the --
 
         13       Q.   When your daughter --
 
         14       A.   Oh, okay.
 
         15       Q.   You got a call, and where did you go?
 
         16       A.   I got a call from Robin that night, she had run to some
 
         17    elderly people's house on the corner.  And when I got there, she
 
         18    was sitting in the police's car, she had on her bed clothes and
 
         19    bare foot.  It was cold, and I said where is your car, and she
 
         20    said Mark got it, we couldn't get in because there were no keys.
 
         21       Q.   Where were the keys?
 
         22       A.   Mark had them.
 
         23       Q.   So what did you do that night?
 
         24       A.   I took her home, she went home with me.
 
         25       Q.   And then what did you do next?
 
 
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          1       A.   That next day?
 
          2       Q.   (Nods head.)
 
          3       A.   We went down to the relators office and got the key so
 
          4    that they could get in.
 
          5       Q.   State whether or not you know if your daughter ever
 
          6    called down to Charlotte on that day?
 
          7       A.   She called that day.
 
          8       Q.   And what was the purpose?
 
          9       A.   She talked to his mother.  And I -- she told his
 
         10    mother --
 
         11            MR. LAUGHRUN:  Objection.
 
         12            BY MR. CONRAD:
 
         13       Q.   Did you hear that conversation?
 
         14       A.   I heard that conversation.
 
         15       Q.   I just want you to talk to me about part you heard, what
 
         16    did you hear Robin say?
 
         17            MR. WILLIAMS:  Objection.
 
         18            THE COURT:  Overruled.
 
         19            BY MR. CONRAD:
 
         20       Q.   What did you hear?
 
         21       A.   That he was not welcome back in her apartment, he could
 
         22    not stay there anymore:
 
         23       Q.   Now after you got a new key from the landlord, what did
 
         24    you do?
 
         25       A.   Robin and I and her uncle went out and bought new locks
 
 
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          1    to put on the door.
 
          2       Q.   Would that be uncle Ray?
 
          3       A.   Uncle Ray.
 
          4       Q.   Okay.  And did you put new locks on the door?
 
          5       A.   We put new locks on the door.
 
          6       Q.   State whether or not anything else happened on that day
 
          7    that was unusual?
 
          8       A.   Well, on that day that was unusual?  She stayed around
 
          9    and they put locks on the doors, and about 11:00 or 1:00 that
 
         10    morning, the phone rang and it was Mark.  He had come back, you
 
         11    know, to bring her car and a U-haul.  I previously told her that
 
         12    if the car wasn't back on Thursday morning that I was going to
 
         13    report it stolen.  I did not report it stolen because she
 
         14    wouldn't let me, she said Mommy, he will bring it back.
 
         15       Q.   Had you cosigned on that car?
 
         16       A.   Yes, I had.
 
         17       Q.   Prior to that phone call, did you or her notice anything
 
         18    about her property at her house?
 
         19       A.   Everything was intact, everything in the house was
 
         20    intact.  She had, you know, her TV, and everything was in the
 
         21    house when we locked it up.
 
         22       Q.   Did something happen after that?
 
         23       A.   When she got there, well, he called at 1:00 that morning
 
         24    and asked her why did she change the locks on the door.  She
 
         25    said because I didn't want you to take my stuff.  She went on
 
 
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          1    back to bed.  I had to go to work the next day, but when she got
 
          2    there, the next morning, her VCR was gone.  And she called the
 
          3    police, the police came but the police never did do anything.
 
          4       Q.   In addition to her VCR gone, was anything done to her
 
          5    clothes if you know?
 
          6       A.   Her clothes were covered with bleach, her clothes, all
 
          7    of her clothes were covered with bleach, there was syrup, syrup
 
          8    and bleach poured down through her TVs, all of the clothes that
 
          9    she had she had to throw away.
 
         10       Q.   Did she come back to stay with you?
 
         11       A.   She came home and she stayed home a whole month, almost
 
         12    a month, and she stayed home.  And the first night she went home
 
         13    because she had to buy a bedroom suit, she got all of the
 
         14    clothes washed up.  The first night she went home, that was at
 
         15    the --
 
         16            THE COURT:  You want to take a recess at this time.
 
         17            MR. CONRAD:  Yes, judge.
 
         18            THE COURT:  Members of the jury, do not discuss the case
 
         19    among yourselves while you are out.
 
         20            (The jury left the courtroom.).
 
         21            THE COURT:  You may step down, Ms. Williams, recess
 
         22    until 3:00.
 
         23                      (Brief recess.)
 
         24            THE COURT:  Ready for the jury?
 
         25            MR. WILLIAMS:  If Your Honor, please, defense counsel
 
 
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          1    would like to be heard in the absence of the jury.
 
          2            THE COURT:  All right, sir.
 
          3            MR. WILLIAMS:  Briefly, Your Honor, the defense renews
 
          4    its objection to the statements of Robin Williams as testified
 
          5    to by Bertha Williams.  Our objection is based on Rule 804,
 
          6    subsection five where the declarant is unavailable, and if Your
 
          7    Honor please briefly, our objection is based on the fact that
 
          8    the government has previously put us on notice of a recorded
 
          9    statement under Rule 807 of Robin Williams that we exchanged
 
         10    briefs and argued previously and court ruled that that would
 
         11    come in.
 
         12            The government gave us notice of that, the government
 
         13    has not given us notice of any other testimony concerning Robin
 
         14    Williams' statements as required under Rule 804, and therefore,
 
         15    these statements are objectionable.  We respectfully argue under
 
         16    Rule 804 to strike any statements made by Bertha Williams
 
         17    concerning Robin Williams that do not deal with the 807
 
         18    material.  And we renew our objection and move to strike.
 
         19            THE COURT:  Government.
 
         20            MR. CONRAD:  Your Honor, the objection under 804 (b)(5)
 
         21    is not proper because that rule has been abolished, and we're
 
         22    working with Rule 807, we did file a motion or a notice of
 
         23    intent to use unavailable witness hearsay under Rule 807, gave
 
         24    notice to counsel, briefed it.  That motion included not only
 
         25    the recorded interview with Detective Kahl but also other
 
 
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          1    statements made by Robin Williams to family members, to friends,
 
          2    and to health care providers.  We also filed a memorandum with
 
          3    respect to admitting evidence of prior relationship between
 
          4    Robin Williams and the defendant Mark Barnette, and the Court
 
          5    issued an order permitting that kind of testimony.  And we gave
 
          6    proper notice and you allowed it.
 
          7            And I have tried very hard with this witness to confine
 
          8    her testimony about what people told her, solely to what Robin
 
          9    told her and not what she heard from other people.  And I think
 
         10    that's within the scope of your order and it should be admitted
 
         11    and not stricken.  Thank you.
 
         12            THE COURT:  All right, sir.  I worked real hard on that
 
         13    order, Mr. Williams, objection will be overruled on that point.
 
         14    Call the jury.
 
         15            (The jury returned to the courtroom.)
 
         16            THE COURT:  If you could pick up the microphones, that
 
         17    way if I don't hear you --
 
         18            MR. WILLIAMS:  I'm sorry, Judge, I will speak up.
 
         19            THE COURT:  Mr. Conrad.
 
         20            MR. CONRAD:  Thank you Your Honor.
 
         21            BY MR. CONRAD:
 
         22       Q.   If I could turn your attention now to the night of your
 
         23    daughter's fire bombing.  I believe you mentioned you got a
 
         24    call, what did you do after you received the call in the early
 
         25    morning hours?
 
 
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          1       A.   I woke my brother and I told him, let's go, Robin's
 
          2    apartment is on fire.  We got in the car and went down.
 
          3       Q.   Did you see Robin there?
 
          4       A.   Yes, she was in the ambulance when I got there.  When I
 
          5    got to the ambulance, she yelled, mommy, I'm all right.
 
          6       Q.   Did you go with her to the UVA Burn Center?
 
          7       A.   Yes, I did.
 
          8       Q.   Did you stay with her there?
 
          9       A.   Yes, I did.
 
         10       Q.   Did you stay there the whole time with her?
 
         11       A.   Stayed there the whole time.  I left one day and stayed
 
         12    gone about five hours, but I come back.  I had business, but I
 
         13    was back before night fall.
 
         14       Q.   And you came back to Roanoke to do what?
 
         15       A.   For business.
 
         16       Q.   When you -- when she was released from the hospital, did
 
         17    she come back to Roanoke?
 
         18       A.   She came home.
 
         19       Q.   And did she live with you there until her death?
 
         20       A.   She stayed with me until her death.
 
         21       Q.   Now, turning your attention to that day.  Would you tell
 
         22    the jury what happened in the early morning hours of June 22nd?
 
         23       A.   I got up around 6:00, came downstairs, we went out on
 
         24    the porch to sit and wait on my grand baby.  She was supposed to
 
         25    have been there at 6:30.  She was late.  So I was reading the
 
 
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          1    paper.  After she came I went on back inside, set her down in
 
          2    the den in front of the TV.  She was 8 months old.  I went in
 
          3    the kitchen and made a batch of brownies, put those in the
 
          4    stove, and it was about 7:00, I remember looking at the clock
 
          5    because I had to time my brownies.
 
          6            And after I put the brownies in the stove, I walked in
 
          7    the den and sat down, and I heard a big bang.  And I said, God
 
          8    oh mighty, my stove must be blowing up.  I didn't know at
 
          9    that -- well, I got up and I looked and I sat back down, and I
 
         10    heard a bang again.  Well, I didn't get up that time.  Then I
 
         11    heard another bang, and I got up and I looked.  And I said to
 
         12    myself, somebody must be shooting at my door.  By the time I
 
         13    turned around, Robin was at the bottom of the steps, and she
 
         14    said, mama, what is it?  And I said I don't know, somebody is
 
         15    shooting at the door.
 
         16            And I said -- I picked up my baby and stepped out the
 
         17    front door and looked around, but I couldn't see the back door,
 
         18    and I said I don't know what it is, Robin, it must be Mark.  And
 
         19    she started turning around and around on the floor, she didn't
 
         20    know which way to go.  And she said, mama, what do I do?  And I
 
         21    said, I don't know baby, I said, run, just run.  And I was
 
         22    standing in the door holding my baby.  Out the door she went,
 
         23    and when I turned around there was Mark looking me at my face,
 
         24    he had that gun in his hand and he did like that (indicating),
 
         25    throwed it this way.  And I said Mark, don't shoot my grand
 
 
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          1    baby.  He said, where is she?  And I said she's gone running,
 
          2    leave her alone.  Out the door he took.  I set the baby down in
 
          3    the hall and run back to the den and picked up the phone and it
 
          4    was dead.
 
          5            By this time my brother was trying to get down the
 
          6    steps, and he said what is the matter?  And I said Mark is here
 
          7    and he's after Robin with a gun.  I run out on the porch and I
 
          8    started screaming, please, somebody please, call 911.  And I
 
          9    went back in the house and picked up the phone again, and it was
 
         10    dead.  And I ran back out the front door and run out the in the
 
         11    yard, went across the street, run around the side of the
 
         12    apartment house, and Mark was coming down the hill dragging
 
         13    Robin.  And I said, Mark, leave her alone.  I said, you have
 
         14    already disfigured her for life, leave her alone.  He was just
 
         15    pulling her by the hair, and he said, I'm going to kill her.  He
 
         16    said, I'm going to kill you, I'm going to kill myself.  And then
 
         17    he started talking about the police, he started talking about
 
         18    some attempted murder, and he started rattling and rattling.
 
         19            And as he was pulling her on down the hill, I walked
 
         20    across the grass, they were stopped at the utility box and I
 
         21    walked across the grass, walked over to Robin and got her by the
 
         22    arm, I was leading her back across the street, and he started
 
         23    saying something to Sonji on the porch, she was on the phone,
 
         24    and just as we got ready to step up on the grass there was a
 
         25    shot.  I jumped and Robin put up her hands.  I looked back at
 
 
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          1    Mark and he was doing this (indicating), and just as she
 
          2    started, I looked back at Robin just as she started to move her
 
          3    feet as if to walk or run, he shot again and she fell.  She
 
          4    fell, and she fell right down beside me and I fell down on my
 
          5    knees and I said, oh, God, she is shot in the side, and I got
 
          6    down and I looked at her side and I didn't see anything.  And I
 
          7    pulled up her arm, and in here (indicating) she had a hole, and
 
          8    you could see the debris, her flesh was hanging.  And I grabbed
 
          9    her and I said Robin, I said hold on baby, hold on.  She was
 
         10    gasping for breath.  And I run, I said give me a phone, give me
 
         11    a phone.  And Sonji said, I don't have a cordless phone, and I
 
         12    run up the stairs and I got her phone and I called my pastor,
 
         13    and I said pray, pray, I said this boy shot my baby.
 
         14            I hung up, and I called her brother, Kenny, and I got my
 
         15    daughter, I said y'all come, Robin's been shot.  And I ran back
 
         16    to her, and when I got back down to where she was, I got down to
 
         17    her, she said (gasping noise), and she never said no more.  And
 
         18    I screamed, and I screamed, and screamed.  I just started
 
         19    praying, and I just prayed asking God, please don't let my baby
 
         20    die, oh, Lord don't let her die.  And I screamed, and I
 
         21    screamed, and I screamed.  And the officers kept saying she is
 
         22    all right, and I said please don't let her die.  And somebody
 
         23    come and got me and took me home.
 
         24       Q.   Ms. Williams, can I ask you one question.  When that
 
         25    first shot occurred, how close were you to Robin?
 
 
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          1       A.   She was standing right beside me, we were both stepping
 
          2    on the knoll of the grass.  And when she fell, she fell at my
 
          3    feet.
 
          4            MR. CONRAD:  That's all I have, Judge.
 
          5            THE COURT:  Any questions?
 
          6            MR. WILLIAMS:  I'm sorry.  No questions.
 
          7            THE COURT:  Thank you.
 
          8            MR. WILLIAMS:  I'm sorry.
 
          9            THE COURT:  Do you have another witness this afternoon?
 
         10            MR. CONRAD:  No.
 
         11            THE COURT:  Members of the jury, I told you I was going
 
         12    to let you go at 4:00 or 4:30, again we have a witness who is
 
         13    coming and can't get into here until tomorrow about 7:30, so I'm
 
         14    going to let you go early today.  And we'll see you in the
 
         15    morning at 9:30.  Do not discuss the case among yourselves or
 
         16    anyone outside of the courtroom, do not read anything about it,
 
         17    don't look at anything on TV, don't let anybody talk to you
 
         18    about it.  Have a nice evening, see you in the morning at 9:30.
 
         19            (The jury left the courtroom.).
 
         20            MR. WALKER:  Your Honor, quick item while I think the
 
         21    jurors are still in the jury room.  I believe I saw a couple of
 
         22    jurors take their notes with them into the jury room right then
 
         23    and I don't know if they were supposed to leave those in the
 
         24    chair.
 
         25            THE COURT:  Really should leave them out here,
 
 
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          1    I -- Sammy, go on in there and ask if they have any notes.
 
          2            MR. WALKER:  That was all I wanted to address the Court
 
          3    about.
 
          4            THE COURT:  Let's see, I believe we have one more
 
          5    witness, is that right?
 
          6            MR. CONRAD:  Yes, sir, we have the medical examiner who
 
          7    cannot make it until the morning, and that's all the witnesses.
 
          8            THE COURT:  You finish that tomorrow?
 
          9            MR. CONRAD:  Yes, sir.
 
         10            THE COURT:  You gentlemen, are you going to have any
 
         11    testimony or evidence do you think?
 
         12            MR. LAUGHRUN:  Your Honor not in Phase 1, Your Honor.
 
         13            THE COURT:  All right, we will be ready to go to the
 
         14    jury on Monday or Tuesday?
 
         15            MR. LAUGHRUN:  Yes, sir.
 
         16            THE COURT:  You want to work on the jury instructions on
 
         17    Monday and wait until Tuesday?
 
         18            MR. CONRAD:  That's what we would prefer.
 
         19            THE COURT:  All right.  Try to get the jury instructions
 
         20    ready for you on Monday morning and then we'll have the final
 
         21    arguments, closing arguments.
 
         22            MR. LAUGHRUN:  May we present to you our proposed
 
         23    instructions tomorrow afternoon or sometime --
 
         24            THE COURT:  You better give them to me before the
 
         25    weekend.
 
 
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          1            MR. LAUGHRUN:  We will bring them to you in the morning,
 
          2    we have them pretty much ready to go --
 
          3            THE COURT:  Does the government have any?
 
          4            MR. CONRAD:  We will present some to you tomorrow
 
          5    afternoon.
 
          6            THE COURT:  In that case, Monday we will go with the
 
          7    instructions and go to jury on Tuesday.
 
          8            MR. LAUGHRUN:  Assuming we finish tomorrow.
 
          9            THE COURT:  They say we will.
 
         10            MR. LAUGHRUN:  If we don't finish can we still have the
 
         11    charge conference Monday?
 
         12            THE COURT:  We won't start until Tuesday.
 
         13            All right. See you in the morning at 9:30.  Recess until
 
         14    tomorrow morning at 9:30.
 
         15            (Court in recess.)
 
         16
 
         17
 
         18
 
         19
 
         20
 
         21
 
         22
 
         23
 
         24
 
         25
 
 
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