537

IN THE CIRCUIT COURT OF SHELBY COUNTY,

TENNESSEE FOR THE THIRTIETH JUDICIAL

DISTRICT AT MEMPHIS

_______________________________________________

CORETTA SCOTT KING, et al,

Plaintiffs,

Vs. Case No. 97242

LOYD JOWERS, et al,

Defendants.

_______________________________________________

PROCEEDINGS

November 22nd, 1999

VOLUME V

_______________________________________________

Before the Honorable James E. Swearengen,

Division 4, judge presiding.

_______________________________________________

DANIEL, DILLINGER, DOMINSKI,

RICHBERGER, WEATHERFORD

COURT REPORTERS

Suite 2200, One Commerce Square

Memphis, Tennessee 38103

(901) 529-1999

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

538

- APPEARANCES -

For the Plaintiff: DR. WILLIAM PEPPER

Attorney at Law

New York City, New York

For the Defendant:

MR. LEWIS GARRISON

Attorney at Law

Memphis, Tennessee

Court Reported by:

MR. BRIAN F. DOMINSKI

Certificate of Merit

Registered Professional

Reporter

Daniel, Dillinger,

Dominski, Richberger &

Weatherford

22nd Floor

One Commerce Square

Memphis, Tennessee 38103

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

539

- INDEX -

WITNESS: PAGE/LINE NUMBER

TAPE OF DEXTER KING/ANDREW

YOUNG/LOYD JOWERS PLAYED

TO THE JURY........................... 542 19

ARTHUR HAYNES, JR.

DIRECT EXAMINATION

BY MR. PEPPER......................... 645 19

CROSS-EXAMINATION

BY MR. GARRISON:...................... 662 24

REDIRECT EXAMINATION

BY MR. PEPPER:........................ 667 21

BOBBIE BALFOUR

DIRECT EXAMINATION

BY MR. PEPPER:........................ 671 9

CROSS-EXAMINATION

BY MR. GARRISON:...................... 680 2

REDIRECT EXAMINATION

BY MR. PEPPER:........................ 682 21

RECROSS-EXAMINATION

BY MR. GARRISON:...................... 684 4

WILLIAM R. KEY

DIRECT EXAMINATION

BY MR. PEPPER:........................ 684 20

JOE B. BROWN

DIRECT EXAMINATION

BY MR. PEPPER:........................ 690 23

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

540

(November 22nd, 1999, 10:15 a.m.)

THE COURT: Mr. James, would you

bring the jury out, please.

(Jury in.)

THE COURT: Good morning, ladies

and gentlemen. Glad to see that all of you

survived the weekend. We're going to proceed

with our trial at this point.

Mr. Pepper, what's your next order

of proof?

MR. PEPPER: Yes, Your Honor.

If it please the Court, we'd like to --

plaintiffs would like to continue where we

left off with Ambassador Young's testimony by

going directly into the tape-recording of the

meeting that he described with the

defendant.

Though the Court may wish to break

from time to time, we -- the plaintiffs feel

it is important for the jury to hear the

entirety of that tape.

THE COURT: I believe you said

Friday it is about two hours long?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

541

MR. PEPPER: We believe it is

about two hours.

THE COURT: It might get too

exciting for us.

MR. PEPPER: We might have to

take a break after an hour or so.

THE COURT: Whatever pleases the

Court. Thank you.

THE COURT: We'll begin with

that. Go ahead.

If you would just explain to the

jury the circumstances under which this tape

was made, where it was and then it might be a

little more meaningful.

MR. PEPPER: The tape was made

approximately a year ago, as Ambassador Young

testified. And it was made here in the State

of Tennessee. The participants at the

meeting were the defendant, Mr. Loyd Jowers,

his attorney, Mr. Louis Garrison, Ambassador

Andrew Young and plaintiff Dexter Scott

King.

They came together for the purpose

really of discussing the underlying cause of

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

542

action in this case, Mr. Jowers' role in

respect to the killing of Martin Luther

King.

While there is introductory

information and some banter occasionally, we

would ask the Court and the jury to listen

carefully to the various questions and the

responses to those questions.

MR. GARRISON: Your Honor, we'd

like to have it started at the very

beginning.

MR. PEPPER: Yes, sir. I've

asked the technician to start it from the

beginning.

THE COURT: All right. Go

ahead.

(Tape played for the jury in

open court as follows:)

"LOYD JOWERS: Dexter, what you

been up to?

DEXTER KING: Well, I've been

keeping busy, working hard, traveling a lot.

LOYD JOWERS: You work a lot at

night, don't you?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

543

DEXTER KING: I do. You

remember. I was working late one night in my

office when I talked to you.

LOYD JOWERS: Yeah.

DEXTER KING: Keeping, you

know, keeping all things moving forward, just

still trying to deal with this issue. This

is a very trying issue, because, as you know,

my family, particularly my mother, I've been

concerned about because the media has been

very vicious --

LOYD JOWERS: Oh, yeah.

DEXTER KING: -- in trying to

discredit and attack, you know, the family.

We had hoped that we would get to the bottom

of this so we can move on. I think in order

to have true closure, you have to get it

out. You have to get it out in the open.

So we appreciate your willingness to

open up and come forward. As you know, we

continue to support immunity for you, but, as

you know, the District Attorney doesn't seem

like they want the story to come out. So it

appears they are shutting everything down.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

544

LOYD JOWERS: Yeah.

DEXTER KING: I think that

would be a major tragedy.

LOYD JOWERS: Oh, it would be,

definitely.

Don't you think so, Mr. Young?

ANDREW YOUNG: I do. In fact,

I think that -- I don't think I would be out

of order in saying if something happened and

you were indicted for anything, then I would

sure be willing to come over here and testify

on your behalf as having been -- as having

been very helpful to us in trying to

understand that. We would want to make sure

that nothing happened to you.

LOYD JOWERS: Well, you know,

this is what I don't understand, and I never

did understand it about President Kennedy:

That they know there has got to be a

conspiracy. Why they won't admit that and go

from there on the basis of prosecution,

whatever they have to do, I don't understand

why they won't do it.

LEWIS GARRISON: Mr. Jowers, Mr.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

545

King and and Mr. Young have read the account

of this that I had written from what you had

and I had talked about. So they want to

question you.

LOYD JOWERS: Okay. Any time

you get ready.

LEWIS GARRISON: Feel free to go

forth.

DEXTER KING: When we last met,

you had pretty much taken us I think up to a

point where you had received the rifle from

Lieutenant Clark.

DEXTER KING: And you thought

it was a 30-30, you said, and you might have

been mistaken, that it was a 30-06.

LOYD JOWERS: I very well could

have been. Let me tell you that I knew he

owned a 30-30. I couldn't swear that that

was Clark that I took it from, but I believe

it was.

Now, see, it happened just about

that quick. (Snap of fingers.) I was at the

back door at six-oh-clock like I was supposed

to be. How many seconds did it take him to

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

546

hand me that rifle and get going? That was

just a split second.

LEWIS GARRISON: You said it was

still smoking?

LOYD JOWERS: Oh, the smoke was

still coming out the barrel of the rifle. I

breached it. Of course, that's what you've

got to do before you break one down.

LEWIS GARRISON: Clark had been

back that night, that afternoon?

LOYD JOWERS: He had been in the

place that day, yeah.

LEWIS GARRISON: Had you seen

him go in the back?

LOYD JOWERS: He went back and

looked out the back. You see, the way the

grill was laid out, up here is where all your

customers are. The kitchen is here. Back

here we've got a storeroom. He walked all

the way back.

Of course, I was there working, you

know. I didn't really pay attention to him.

Of course, he was a friend of mine.

ANDREW YOUNG: You met him by

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

547

the back door by the storeroom?

LOYD JOWERS: You are talking

about that night?

ANDREW YOUNG: Yes.

LOYD JOWERS: Yes, I met him --

yes, I was at the back door.

ANDREW YOUNG: Out of the

storeroom?

LOYD JOWERS: Yeah.

ANDREW YOUNG: And he came up

from the woods back there or bushes?

LOYD JOWERS: From the bushes.

ANDREW YOUNG: And he handed you

the rifle?

LOYD JOWERS: About that quick.

All I got was a glance of him. I had the

back door standing open. I didn't have to

open the door or anything. It was standing

open. The rifle was smoking.

I'll put it like this: I thought it

was a 30-30. I didn't examine it. I didn't

have time. All I done was get that empty

shell out of it, and there were no other

shells in it but that one. That's all that

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

548

was in there.

The rifle was smoking. I broke it

down right quick, put it up under my apron,

walked up to the front, set it underneath the

counter. I wrapped it in a table cloth

first.

I stuck it under the counter and

went on up to the front of the building. By

the time the police got there, it took them

about two, two and a half minutes to get

there, I didn't have time to see nobody or do

nothing getting up there that quick. Of

course, I was working by myself.

ANDREW YOUNG: You had heard

the shot before you went to the back?

LOYD JOWERS: No, I was already

in the back.

ANDREW YOUNG: You were already

in the back at six-oh-clock?

LOYD JOWERS: Yeah.

ANDREW YOUNG: You heard the

shot from from back there?

LOYD JOWERS: One shot is all I

heard.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

549

LEWIS GARRISON: You'd been told

to be back there at six, hadn't you?

LOYD JOWERS: I had been told to

be back there at six, yeah, that a man was

going to pass me a package. He didn't tell

me what it was. I certainly didn't know he

was going to shoot anybody, especially Dr.

King, the fact it turned out to be.

What I would have bet was a 30-30,

but it could have been a 30-06. There is not

that much difference in them if you ever

compared them. There is not that much

difference in them. They both break down

about the same way. I didn't have to break

it down, but I was told to --

ANDREW YOUNG: Did you used to

go hunting with Mr. Clark?

LOYD JOWERS: Oh, yeah. I went

hunting with him. Never went with him any

more after that, though.

LEWIS GARRISON: You said you

and Mr. Clark worked at the police department

at same time, that you were a police officer

at the same time he was?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

550

LOYD JOWERS: He come on the

police department just a short time before I

got off. But now we went hunting down in

Mississippi pretty regularly, went hunting on

Rex Chenault's place down in Mississippi,

down below Hernando.

ANDREW YOUNG: Is Mr. Clark

still alive?

LOYD JOWERS: I think he is,

isn't he?

LEWIS GARRISON: No, he is dead.

LOYD JOWERS: Oh, is he?

LEWIS GARRISON: His wife is

still living, though. Mr. Barger is dead.

The only one that is still living is

Officer Zachery, who was in and out of the

grill, wasn't he?

LOYD JOWERS: Well, unless I'm

mistaken about this, Officer Zachery was in

charge of the men that was in charge of Dr.

King's security. Now, I could be wrong about

that, but that's what I thought.

LEWIS GARRISON: He was in and

out of the grill some, Officer Zachery.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

551

LOYD JOWERS: Oh, yeah.

LEWIS GARRISON: Merrell

McCullough was there, that's one of the first

ones you ever mentioned?

LOYD JOWERS: McCullough, yeah.

LEWIS GARRISON: How was he

identified? How was he introduced to you,

Merrell McCullough? Who introduced him to

you?

LOYD JOWERS: I don't remember

if it was Clark or Johnny Barger. It was one

or the other of them.

Now, Johnny Barger was my partner.

We were policemen together. He is the one

who introduced me to Frank Liberto. We used

to go there quite often. They was real good

friends.

Of course, I got to be pretty good

friends with Frank, because he could do you a

lot of good in Memphis, especially on the

police department.

DEXTER KING: Did you know

Frank's family, like his wife?

LOYD JOWERS: I met her one

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

552

time, but as far as really knowing her, I

can't say I did. I never was out with her

ever at a party or anything.

DEXTER KING: Do you know her

name?

LOYD JOWERS: I always called

her Ms. Liberto.

LEWIS GARRISON: Is she still

living?

DEXTER KING: Is she still

living?

LOYD JOWERS: I think she is.

Dexter, you do remember I'm hard of

hearing, don't you? I only hear about thirty

percent in this ear. That's the reason we're

taping this, because sometimes I don't get a

question right. If I don't get it right, I

can't answer it right.

LEWIS GARRISON: They took -- I

don't know if you and Mr. Young are aware or

not, but the FBI questioned Mrs. Liberto, who

was the mother of Mr. Liberto, and his

brother, who was on the police force, and

I've got copies of those statements.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

553

DEXTER KING: Was his brother

Charles?

LEWIS GARRISON: A Memphis

police officer. They had a picture of Mr.

Ray. They all asked if they knew him, and

they said they did not but he looked

familiar, like someone they had seen around.

DEXTER KING: When they saw the

picture of Ray you are saying they thought it

was somebody --

LEWIS GARRISON: Mr. Ray claimed

in his deposition he had gone to New Orleans

to meet with Raul. In her affidavit and

also his brother and I believe someone else,

they all said Mr. Ray's face looked familiar.

DEXTER KING: Was the brother a

police officer in New Orleans?

LEWIS GARRISON: Yeah. He is

retired now. He is still there, as far as I

know.

DEXTER KING: Does he have a

business?

LEWIS GARRISON: He may. I'm

not sure, to be honest with you. I'm not

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

554

sure. He is retired from the police

department. He may have a business. I'm not

sure.

DEXTER KING: Do you know

anything about his brother, Charles?

LOYD JOWERS: The one that lives

in New Orleans?

DEXTER KING: I think so.

Charles.

LOYD JOWERS: No, sir. I never

did know Charles. Now, I heard of him.

Frank told me about him. But I never met

him, as far as I can remember. I never met

Charles.

DEXTER KING: What about in Dr.

Pepper's book he talks about the market, I

think L&M or I think L&L, Latch & Liberto?

LOYD JOWERS: Yeah, over on

Scott Street.

DEXTER KING: Okay. I think

there was a Frank Liberto, a produce dealer,

and a Frank Liberto --

LEWIS GARRISON: There were

three of them.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

555

DEXTER KING: There were three.

LEWIS GARRISON: A car salesman,

liquor store owner and produce dealer.

DEXTER KING: I was going to

ask you did you know all of the three or any

of the three?

LOYD JOWERS: The only one I

knew was Frank. He is the one that always

called me. Like I say, I handled that one

hundred thousand dollars for him. But it

wasn't the first time I handled money for

him. But it was the last time.

DEXTER KING: Let me

understand. They would ask you to receive

the money. They would send it over in a

box?

LOYD JOWERS: With my produce,

yeah, in the bottom.

DEXTER KING: Then somebody

would pick it up from you?

LOYD JOWERS: Yeah.

DEXTER KING: Pick up the box.

Okay. Now, in the case of the one hundred

thousand that they sent over, did they tell

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

556

you that it was for, you know --

LOYD JOWERS: They never told me

what -- none of the money I handled for them

over the years, they would never tell me what

it was for, just that it would be in there.

This time they told me how much it was. But

I didn't count it. I did not. I never

counted it.

LEWIS GARRISON: Describe for

them what it looked like, Mr. Jowers.

LOYD JOWERS: Well, it was in

one-hundred-dollar bills. Heck, I don't know

how thick it was. About like that. Two

rubber bands around them, one on each end.

It was in a brown paper bag.

ANDREW YOUNG: It was in with

your vegetables?

LOYD JOWERS: It was underneath

my vegetables, it sure was.

DEXTER KING: Now, who picked

up that box?

LOYD JOWERS: First Frank called

me and told me there will be a Cuban by to

pick it up. He said, you give him that

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

557

package. That's when he told me that there

was a hundred thousand dollars in it.

I told him, said, Frank, you know I

ain't going to count that money. If it is a

hundred thousand, that's fine. If there is

not that much, that will have to be fine,

too.

Then he called me back -- let's

see. That was on a Wednesday morning. Then

he called me back and said, now, that wetback

is going to be by there to get that package

that is going to be handed in that back

door. He called him a wetback. I never

heard a Cuban called a wetback. So I don't

know if it was a Cuban or a Mexican, but it

was definitely a foreigner.

DEXTER KING: Was that Raul?

LOYD JOWERS: That's what they

said his name was. I don't believe that was

his name anymore than I believe yours is Jack

Thomas.

DEXTER KING: Why is that?

LOYD JOWERS: I just don't

believe that. Why would a man use his own

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

558

name when he is involved in something like

that? Why would he do that?

No, he would use Jack Jones or --

but Raul, I was going to look that up and

see what that stands for in a foreign

language. I'm not sure what it stands for.

But it is very common among foreigners.

LEWIS GARRISON: You at first

thought he said Royal, didn't you?

LOYD JOWERS: I thought he said

Royal, I sure did. But he corrected me and

told me Raul. I said, well, whatever.

LEWIS GARRISON: Did you know

any of Frank Liberto's close friends, who his

close friends were?

LOYD JOWERS: Well, the lady

that owned a restaurant out on in Highland

Heights.

DEXTER KING: Is that Lavada

Whitlock Addison?

LOYD JOWERS: Ms. Whitlock,

right. Now, I met her one time back along

about that time. She wasn't all that old a

woman, either. I don't remember what the

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

559

occasion was, but I did meet her. Of course,

I knew Nathan over the years after the

assassination took place. I knew Nathan real

well.

DEXTER KING: That was her

son?

LOYD JOWERS: Pardon?

DEXTER KING: Nathan was her

son, right?

LOYD JOWERS: Yes, sir.

DEXTER KING: Now, he knew

Liberto as well?

LOYD JOWERS: He knew him real

well. See, Ms. Whitlock owned a restaurant

out on Highland Heights, on Macon Road, I

believe. I believe that's where it was.

Frank used to stop in there all the time.

The fact is he tried to go to bed

with her all the time, Mrs. Whitlock. He may

have. I don't know. Anyway, he'd get oiled

up, get drunked up, and he'd do a lot of

talking.

DEXTER KING: Do you know any

other friends of his or were those the only

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

560

two?

LOYD JOWERS: You know, apart

from the people on the police department,

Johnny Barger, I'm not sure if Cross was a

friend of his or not, but I know Johnny

Barger was.

We used to be in a squad car in a

territory and we'd leave our territory and go

over on Scott Street to his place of

business. Sometimes we'd stay but a few

minutes, then other times we'd stay longer

than that.

See, you have to understand that

back then, back then everything was done

politically. If you got anywhere, you had to

know somebody that knew somebody. It is

almost that way now, but it was really,

really bad back then. There was no blacks on

the police department, it was just an unheard

of thing.

ANDREW YOUNG: Was that Crump

time? Was Crump in office back then?

LOYD JOWERS: Oh, yeah. Crump

is the one that got me the job. I went to

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

561

see him on a Monday, and on a Thursday I went

to see the police commissioner. That Monday

morning I was riding in a squad car with a 38

hanging on my side, billy stick hanging on

this side. That's just the way things

operated back then.

ANDREW YOUNG: Were you in the

military?

LOYD JOWERS: I was in the Navy,

yes. I had been discharged out at

Millington, I don't know, less than a year

after I went on the police department.

Jobs were kind of hard to find back

then. They were doubly hard for black

people. It was hard enough for white people,

but it was tough on blacks back then to find

a job.

DEXTER KING: Any other friends

that come to mind of Mr. Liberto's?

LOYD JOWERS: No, I can't think

of any more. I really can't.

DEXTER KING: What about in

Texas, did you know of any of his

relationships with friends in Texas?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

562

LOYD JOWERS: Who? Frank?

DEXTER KING: Yes.

LOYD JOWERS: No, sir, I didn't

know any. I didn't know he had people

there. I knew he had a brother that lived in

New Orleans.

DEXTER KING: So you weren't

aware of any business he may have been in

Texas or New Orleans?

LOYD JOWERS: No.

DEXTER KING: You just knew he

had a brother?

LOYD JOWERS: I knew he had a

brother that lived in New Orleans. I don't

remember who told me. I don't think Frank

told me, but he said he was in the same

business that Frank was in. And by that --

DEXTER KING: You mean produce?

LOYD JOWERS: Yeah. Yeah. And

in the Mafia.

DEXTER KING: When did he first

talk to you about the killing?

LOYD JOWERS: About the killing

of Dr. Martin Luther King?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

563

DEXTER KING: Uh-huh.

LOYD JOWERS: After it took

place. After it took place.

DEXTER KING: The thing I read

is a little confusing from Mr. Garrison, the

part about -- I thought it said that Frank

Liberto was discussing this potential riot or

March beforehand.

LOYD JOWERS: Oh, we talked

about that, sure. But there was no killing

mentioned, no.

DEXTER KING: Okay. But when

he said or alleged that he said that he would

go home with his toes in the air, sticking in

the air or something, sticking up, that if he

comes here, in other words, he will leave

dead, I mean, that's the way I interpreted

it.

LOYD JOWERS: If Frank Liberto

ever told me that, I don't remember. But I

wouldn't doubt him saying that. I would

not. Because that's just the way he was.

DEXTER KING: So you don't

remember talking about the killing until

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

564

actually after it took place?

LOYD JOWERS: If he -- he didn't

mention it until after the fact. I do not

remember.

DEXTER KING: When he did, what

did he tell you, when he finally mentioned

it?

LOYD JOWERS: He asked me a

question. He didn't come down to the place.

He called me on the phone. He said, do you

know what that bundle money was for? I said,

well, I have no idea. He said, well, that's

what it cost me to get King killed.

Word for word, that's what he told

me. I almost dropped the damn telephone.

Well, you know, it surprised me. I figured

it was to buy guns with or dope or whatever

it was he was dealing with.

DEXTER KING: So you were

surprised? You were really shocked?

LOYD JOWERS: I certainly was.

Why, sure I was. Now, if there was no

conspiracy -- let me pass this by you. If

there was no conspiracy, Dr. King, whenever

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

565

he come up to Memphis, he checked into the

Rivermont Hotel where he stayed when he come

to Memphis. Everybody knew that. I knew it,

even. I kept up with him not real close.

You know, the black people that come in my

restaurant, we'd talk about it. I'd carry on

a conversation with them.

The very next day, I think the very

next day, they moved him over to the

Lorraine.

Okay. Now -- I can't remember her

name. Anyway, the lady that runs the place.

DEXTER KING: Ms. Bailey?

LOYD JOWERS: Ms. Bailey. She

put him downstairs. They almost -- I don't

think he stayed downstairs one night. They

almost immediately moved him to the second

floor.

Now, there had to be a conspiracy.

I couldn't have done it. James Earl Ray

couldn't have done it. There had -- it had

to be his security people or the CIA or the

FBI. It had to be.

DEXTER KING: Did you know of

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

566

anybody else who may have mentioned the plot

before, you know, it happened other than

Liberto? I mean, did anybody mention the

possibility that this might happen or that it

was going to happen to you?

LOYD JOWERS: I don't remember

anyone mentioning it black or white. I

really don't. I had about half my

customers -- I'm talking about overall about

half black and half white, because I was in a

mixed neighborhood. Which was fine with me.

I didn't care what color they were. You

know, I always tried to see that everybody

had enough food when they left. But to my

knowledge, no one ever mentioned that.

ANDREW YOUNG: Mr. Jowers, do

you mind saying how old you are now?

LOYD JOWERS: I'm just passed

seventy-one. November 20th I'll be

seventy-two. I have glaucoma in both eyes.

I've got a cataract on this one.

ANDREW YOUNG: But you are

looking pretty fit, though?

LOYD JOWERS: I am. I exercise

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

567

every day. I do. I exercise every day.

Hell, I may live to be a hundred, but I don't

believe it. I smoke two packs of cigarettes

every day.

LEWIS GARRISON: You told

Mr. King before about a meeting that was held

in your place where some people identified

themselves as --

LOYD JOWERS: Yeah. Do you

remember me telling you that?

DEXTER KING: I do.

LOYD JOWERS: About these

policemen meeting there.

LEWIS GARRISON: The CIA and

FBI -- (Inaudible).

LOYD JOWERS: The CIA and the

FBI were there, but they weren't there the

same time all those policemen were there.

They were not there at the same time. But

that wasn't unusual. Cab drivers would meet

in there, policemen met in my place.

ANDREW YOUNG: This is all

before Dr. King was killed?

LOYD JOWERS: Oh, yeah, this

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

568

all took place before. Very rarely did they

have any more meetings after the -- if a

policeman came in, it would be be Johnny

Barger or Clark or someone like that that

would just stop in for a minute.

DEXTER KING: So did you ever

overhear anything that they were saying or

did you have a sense for what they were

meeting about?

LOYD JOWERS: Now, I would be

working. You know how it is in a

restaurant. I would be working and I'd pick

up a word. I wouldn't know what the meeting

was about. What was discussed, I couldn't

say. Of course, I would only get a word now

and then from going by the table.

DEXTER KING: Now, you said

they didn't meet together. You mean the

Memphis police met separately from the CIA?

LOYD JOWERS: In the past,

yeah. See, this CIA business with the FBI on

my part of it was just guesswork, because

they always wear plain clothes.

ANDREW YOUNG: Did they come

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

569

together, the FBI and CIA?

LOYD JOWERS: Yeah, they was

together.

ANDREW YOUNG: But not with

the --

LOYD JOWERS: They were not with

the -- now, there was one stranger who was

with the police that I never seen before or

after the meeting. That was with Johnny

Barger and Clark. I just don't remember who

all was at that meeting. Like I say, I was

working. They had been there spending

money. Of course, I waited on them.

LEWIS GARRISON: How many times

was Merrell McCullough there before this?

LOYD JOWERS: How many times

what now?

LEWIS GARRISON: How many times

was Merrell McCullough in there before this

meeting?

LOYD JOWERS: How many times was

he in there? I can't remember. He could

have been in there when I wasn't even

around.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

570

LEWIS GARRISON: But you saw him

in there several times?

LOYD JOWERS: I saw him several

times, sure.

LEWIS GARRISON: He was

introduced to you as a police officer, wasn't

he?

LOYD JOWERS: Yeah.

LEWIS GARRISON: Johnny Barger

told you that was his assistant or --

LOYD JOWERS: I believe he was a

sergeant at that time.

LEWIS GARRISON: Barger?

LOYD JOWERS: No.

LEWIS GARRISON: Merrell

McCullough?

LOYD JOWERS: McCullough. I

believe he was a sergeant when Dr. King got

killed. I think he was.

LEWIS GARRISON: Was he in a

police uniform when you saw him?

LOYD JOWERS: No.

LEWIS GARRISON: He was not?

LOYD JOWERS: No. He was

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

571

plainclothed whenever he would come in the

restaurant. I never did see him in his

uniform. Now, Johnny Barger always came in

his uniform.

DEXTER KING: Tell me again,

because I just want to make sure I've got the

details down, when you received the money,

who brought the produce to you, the produce

box?

LOYD JOWERS: One of Frank's

regular drivers. I don't recall his name, I

really don't, if I ever knew his name.

DEXTER KING: Do you remember

when you received it, what date and time,

that kind of thing?

LOYD JOWERS: Yeah. They

brought my produce on Wednesday.

DEXTER KING: Okay. This was

afternoon or --

LOYD JOWERS: Yeah, it would be

in the afternoon. I opened up about five

o'clock, got lunch ready, I wouldn't go home

until four o'clock in the afternoon.

DEXTER KING: Then Frank called

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

572

you that afternoon?

LOYD JOWERS: Yeah.

DEXTER KING: To ask you

whether you received it?

LOYD JOWERS: Yeah.

DEXTER KING: What did he say

about the money?

LOYD JOWERS: He described

this -- he called him a Cuban the first time,

then he called him a wetback after that. So

I don't know. He was a foreigner, anyway.

DEXTER KING: What did he say

about the money? He just said the money was

in the box?

LOYD JOWERS: Yeah. He didn't

tell me where. I knew it was hid then the

bottom of it

DEXTER KING: He asked you if

you had counted it?

LOYD JOWERS: Yeah.

DEXTER KING: You said no, you

weren't going to count it?

LOYD JOWERS: That's the first

and last, only time, he ever asked me if I

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

573

had counted it.

DEXTER KING: Okay. But then

what did he say you were supposed to did with

the money?

LOYD JOWERS: He said put it up

until tomorrow, there will be a wetback or a

Cuban by there to pick it up. I said, well,

okay. So I put it in the old cook stove I

didn't use, because nobody ever went in

there, and I knew they didn't. But they

couldn't have got by me anyway.

DEXTER KING: So did the Cuban

come and pick it up?

LOYD JOWERS: Yeah, the next

any. The next day.

DEXTER KING: That's the person

that is alleged to be Raul?

LOYD JOWERS: Yeah.

DEXTER KING: Was that your

first time ever seeing him?

LOYD JOWERS: If he had ever

been in there before then, I didn't know it.

Now, I won't tell you he wasn't in there, but

I didn't know if he was.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

574

DEXTER KING: So you just gave

him the money panned that was it?

LOYD JOWERS: Sure. He walked

on out the door. Same way when he come and

picked that rifle up I took in the back

door. He come in, picked it up, hit that

door, turned right north on Main Street, and

I haven't seen him anymore since then.

DEXTER KING: That was Clark?

LOYD JOWERS: No, I'm talking

about Raul.

DEXTER KING: I'm sorry. I was

confused. You said you haven't seen him

since he came to the back door. Is that what

you said?

LOYD JOWERS: I'm talking about

the guy that picked the rifle up the next

day, the one that actually --

DEXTER KING: Is that the same

guy you gave the money to?

LOYD JOWERS: Yes, same guy.

DEXTER KING: Same guy?

LOYD JOWERS: Same guy.

DEXTER KING: Okay.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

575

LOYD JOWERS: Now, they said it

his name was Raul. It could have been.

DEXTER KING: What's confusing

is I think that -- I thought that the person

who picked up the money was different from

the person who picked up the rifle.

LOYD JOWERS: No.

DEXTER KING: It was the same

person?

LOYD JOWERS: Same person.

ANDREW YOUNG: But a different

person gave you the rifle?

LOYD JOWERS: Oh, yeah,

definitely.

ANDREW YOUNG: Who gave you the

smoking rifle?

LOYD JOWERS: That was a white

man that gave me the rifle. I could see that

much.

LEWIS GARRISON: Wait a minute,

Mr. Jowers. You are getting confused. You

are talking about after the shot was fired?

LOYD JOWERS: Yeah.

LEWIS GARRISON: A white man

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

576

gave you -- this white man gave you a rifle

after the shot was fired?

LOYD JOWERS: Yeah, in the back

door.

LEWIS GARRISON: You are pretty

sure that's Clark?

LOYD JOWERS: I'd almost swear

to it. But now as far as getting a good look

at him, I did not, because the thing really

took (snapping of fingers) that fast.

LEWIS GARRISON: But the person

who brought the gun in was the one he called

a wetback?

LOYD JOWERS: Yeah.

LEWIS GARRISON: Then the person

when came back and got it was --

LOYD JOWERS: The same person,

sure was.

ANDREW YOUNG: Let's see.

We've got three trips: One that they came to

pick up the money. That was the same man

that brought you the rifle?

LOYD JOWERS: The same man that

picked it up, yeah.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

577

ANDREW YOUNG: He brought you

the rifle?

LOYD JOWERS: Yeah.

ANDREW YOUNG: He picked up the

money. Then he came back and picked up the

rifle?

LOYD JOWERS: Now, wait a minute

now. There is a misunderstanding here

somewhere. I never seen a rifle in my

restaurant until after the killing.

LEWIS GARRISON: You said they

brought in a box.

LOYD JOWERS: There was a box.

How would I know? It had never been opened.

I don't know what it was. Now, there was a

box.

LEWIS GARRISON: A long box?

LOYD JOWERS: It was big enough

for that rifle to go in.

ANDREW YOUNG: Raul brought

that -- I mean the Cuban had brought that

box?

LOYD JOWERS: The same guy.

There are three trips he made.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

578

ANDREW YOUNG: Okay.

LOYD JOWERS: That's right.

DEXTER KING: Okay. So he

brought the box after the produce was

delivered, the long box?

LOYD JOWERS: Yeah, he brought

that separate.

DEXTER KING: But he didn't

deliver the produce?

LOYD JOWERS: No.

DEXTER KING: That came from

Frank's market?

LOYD JOWERS: Frank Liberto.

LEWIS GARRISON: You bought from

them pretty regularly? You bought all your

produce from them, didn't you?

LOYD JOWERS: The same driver,

yeah. It was the same driver.

LEWIS GARRISON: How long had

you owned Jim's Grill at that time?

LOYD JOWERS: I opened that

grill up I believe in either late 1966 or

early 1967.

LEWIS GARRISON: You had been

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

579

buying produce from this same place all the

time?

LOYD JOWERS: Yeah. If Frank

didn't have something, I would get it from --

ANDREW YOUNG: Do you remember

what it was, what kind of produce it was with

the money?

LOYD JOWERS: That day?

ANDREW YOUNG: Uh-huh.

LOYD JOWERS: If I thought about

it long enough, I could remember. Well, I

know I ordered three or four stalks of

celery, because I was going to have soup.

You have to have celery to go in soup.

Anyway, I know that celery was in there and

maybe a head or two of lettuce. Just what

you would use in a restaurant.

DEXTER KING: Then when he

brought the long box -- when was that

brought?

LOYD JOWERS: What time of day?

DEXTER KING: Was this the same

day?

LEWIS GARRISON: Was it the

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

580

same -- are you talking about the same day he

brought the produce in?

DEXTER KING: Right. The same

day?

LOYD JOWERS: You know, I don't

believe it was. I don't think there was but

that one delivery that day. You know, I

don't believe that long box was brought when

I was -- you know, I believe that long box

was brought when I wasn't there. That would

have been the next day. That would have been

the day that Dr. King got killed.

DEXTER KING: Who came and got

the long box? Who came and got the rifle?

How did they get the rifle?

LOYD JOWERS: If it was a

rifle. If it was a rifle.

DEXTER KING: Okay.

LOYD JOWERS: Raul would have

had to have picked it up. He had to come

after it, because I never give that long box

to no one else.

DEXTER KING: Where did you put

it?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

581

LOYD JOWERS: Under the

counter. Under my -- you know, you have a

long counter. I put it up under the

counter. Now, it wasn't wrapped up or

anything. It was just along box. It was

about that thick, about that wide. It wasn't

all that long. Maybe as long as this table.

DEXTER KING: They told you to

store it?

LOYD JOWERS: Just hold on to

it.

DEXTER KING: So they came back

to get it when you weren't there?

LOYD JOWERS: I don't remember

giving it to anyone, I don't. I do not.

ANDREW YOUNG: And the police

never searched your store?

LOYD JOWERS: No, never. I

talked to one. He said he was FBI. That's

the next day.

ANDREW YOUNG: But they never

searched your place?

LOYD JOWERS: No, sir.

ANDREW YOUNG: Never looked

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

582

back in the back in the storeroom?

LOYD JOWERS: No, sir. To my

knowledge -- it had a full basement

underneath that place. To my knowledge, they

never went down there. As far as I know,

they didn't.

Now, I thought that was kind of

strange. There could have been a half dozen

people down in that basement, you know. Of

course, there wasn't nothing down there.

DEXTER KING: Who owned the

produce company that sent you the vegetables?

LOYD JOWERS: Who owned it?

DEXTER KING: Who owned it?

LOYD JOWERS: Well, I always

believe Frank Liberto owned it. But that

don't mean he did. He always said he owned

it, anyway.

DEXTER KING: Did Latch have

any --

LOYD JOWERS: I don't know. I

can't answer that.

DEXTER KING: Did you know

Latch?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

583

LOYD JOWERS: Pardon.

DEXTER KING: Latch, do you

know Latch? Is he still living?

LOYD JOWERS: No. I met him one

time. As far as knowing anything about him,

I don't.

DEXTER KING: I wanted to go

back to the meeting with McCullough. Did he

come in with the Memphis Police officers or

with the Feds?

LOYD JOWERS: No, he come in

with the Memphis Police. I believe there was

a total amount of five. The reason I say

that, we had two people sit here and two over

here at a booth, and I took them a chair, so

there had to be five.

I know one I had seen -- I know one

I had never seen before and haven't seen him

since. Now he could have been FBI, could

have been CIA. I don't know.

DEXTER KING: You never heard

their conversation, but you had a sense of

what they were meeting about?

LOYD JOWERS: I knew it was

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

584

something illegal. I knew that part of it.

I would pick up a word now and then. I knew

they were up to something illegal, sure I

did. I wasn't really too concerned about it

because I didn't want to know about it. I

really didn't.

DEXTER KING: Did anybody else

see the money that you received?

LOYD JOWERS: Yeah. Betty

Spates says she saw it. Now, whether she did

or not, I don't know.

LEWIS GARRISON: One of the

other ladies that worked there?

LOYD JOWERS: She described it

to me.

LEWIS GARRISON: Her sister?

LOYD JOWERS: I'm almost sure

she saw it.

LEWIS GARRISON: Two of them

did.

DEXTER KING: How would she

have seen it? Did she go and look in the --

LOYD JOWERS: She would have had

to have opened that oven up, the old stove,

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

585

and looked at it.

LEWIS GARRISON: We have taken a

deposition from her.

DEXTER KING: Now, Betty Spates

was the black waitress?

LOYD JOWERS: Yeah.

DEXTER KING: And you had a

relationship with her. Is that correct?

LOYD JOWERS: That's true.

DEXTER KING: Would she have --

I'm wandering around a little bit because I'm

going off my memory.

LOYD JOWERS: I'm following you

pretty good. Go ahead.

DEXTER KING: Did she say that

she saw you run in with the rifle?

LOYD JOWERS: She said that,

Dexter, but she couldn't have because she was

not there that night. She was not.

Now, I was the only one working that

night. If Harold Parker was still living, he

would tell you that. He would also tell you

I went to the back door at six o'clock, too.

He was sitting -- there a row of booths

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

586

here. He was sitting sitting in the back

booth, and the back door was down here. And

the back door was standing open.

DEXTER KING: What did Frank

tell you about the murder weapon? I remember

before we met -- when we met before, he said

something about he said it was his property.

LOYD JOWERS: He said it was

his, yeah, he sure did.

DEXTER KING: But that was

after you retrieved it and put it under --

well, let me ask you.

LOYD JOWERS: When he told me

that, I had already given i to Raul or

whatever his name was.

DEXTER KING: The next day?

LOYD JOWERS: He didn't tell me

the next day, I don't think. Two or three

days later after that I talked to him.

DEXTER KING: No. I'm saying

when did you give it to Raul?

LOYD JOWERS: I give it to him

early the next day, sure did.

DEXTER KING: April 5th?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

587

LOYD JOWERS: Yeah, the very

next day.

DEXTER KING: Okay. But

Liberto didn't know that Raul was picking it

up?

LOYD JOWERS: Oh, yes, he did,

too. I wouldn't have give it to him if

Liberto hadn't told me. I believe he called

him a wetback, he would be there to pick that

package up you got in the back door.

Of course, after the shooting took

place, then I knew what that damn rifle had

done, I really had.

DEXTER KING: You had put it

all together then?

LOYD JOWERS: Sure. It wasn't

very hard to put together. I knew I was

right in the middle of it. So all I could do

from then on was keep my damn mouth shut.

That's what I done. That's what the

Mafia knew I would do. But I don't know. I

don't think we'll ever get any more with it

myself. Well just have to see.

ANDREW YOUNG: McCullough is a

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

588

pretty young man?

LOYD JOWERS: He was young back

then.

ANDREW YOUNG: He will be

around a long time.

LOYD JOWERS: Oh, yeah.

LEWIS GARRISON: That is thirty

years ago. He'd probably be -- (Inaudible).

LOYD JOWERS: Don't he work for

the CIA now?

ANDREW YOUNG: That's what I

thought.

LOYD JOWERS: That's what I

heard.

LEWIS GARRISON: Yeah.

LOYD JOWERS: That's what I

thought. That's what I heard. I didn't know

that for sure.

LEWIS GARRISON: If this was

thirty years ago and -- I think he would have

been in his twenties back then, and this was

thirty years ago.

LOYD JOWERS: I think the only

way we're ever going to be able to prove that

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

589

this conspiracy is to get the FBI and CIA's

records on it. It is common knowledge, white

and black both know, that J. Edgar Hoover

hated Dr. King with a personal passion.

ANDREW YOUNG: But there

wouldn't be any record of it.

LOYD JOWERS: You don't think

they would make records on something like

that?

ANDREW YOUNG: No.

LOYD JOWERS: Well, you are

probably right. It wouldn't be too smart to,

would it? How do you prove it?

ANDREW YOUNG: Well, it is very

difficult to prove. That's the reason why

we've advocated what they did in South

Africa, declare general amnesty and let

everybody come forward and clear their

conscience.

LOYD JOWERS: Now, that would

work if they did that.

ANDREW YOUNG: And it would

help -- I think it would help the country.

LEWIS GARRISON: I do --

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

590

(Inaudible.)

DEXTER KING: Let me ask you,

Mr. Jowers, I know you are really afraid of

being indicted if you come forward, but what

if you were to come to the media, tell your

story, like maybe talk to a reporter who is

friendly, I mean, somebody who we feel would

be sensitive, they wouldn't try to paint you

in a -- you know, in a negative light, but

just tell the story the way it happened, not

the way you've been dealt with in the past,

you know, by some of the media.

LOYD JOWERS: Yeah, right.

DEXTER KING: But what if they

did a print story first and then you followed

that up immediately, like let's say the story

came out in the morning and you call a press

conference that day and you told your story

in front of a host of reporters where they

can't isolate you, you know, like with ABC

Prime Time and Turning Point, you know, they

could control the message, whereas if you do

you it in a live press conference, they can't

edit it, they can't spin it in a way that

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

591

they want it to be, how would you feel about

that?

LOYD JOWERS: If I thought it

would do any good, I'd do it in a minute. I

think what it will do -- I'm going to tell

you what I think, Dexter. If I thought it

would do any good, I would do it in a

minute. But let me tell you, if I do that

without immunity, the first damn thing a

prosecutor in Memphis is going to do is get

me indicted.

Now, you can just believe that or

not, but that's what will happen. He has

already said he has got enough evidence to

indict me but he don't have enough evidence

to get a conviction. That's the reason I'm

not indicted right now. I guarantee you it

is.

ANDREW YOUNG: They would

indict you for being part of a conspiracy?

LOYD JOWERS: Yeah, they sure

would.

LEWIS GARRISON: They did make

that statement.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

592

LOYD JOWERS: Sure they did.

The fact is I've investigated it. I had four

or five beers in my belly, and I called him.

I said, you son-of-a-bitch, do you think I'm

scared to you? You are wrong.

DEXTER KING: Was this Cook?

LOYD JOWERS: What was that

guy's name?

LEWIS GARRISON: Glankler?

LOYD JOWERS: Mark Glankler.

That's who it was. I sure called him, got

him out of a meeting. I told him, I said,

hell, I'll come over and talk to you in a

minute.

LEWIS GARRISON: They never did

talk to you?

LOYD JOWERS: Ug-huh. He didn't

have a whole lot to say. I went off on him.

I sure did do it.

LEWIS GARRISON: From the time

this occurred on April 4th, 1968, they never

talked to you about any part you had in it?

LOYD JOWERS: No, never have.

Whenever I went down to the police station

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

593

the next day -- maybe it was the next day. I

think it was on the 6th. I went down and

gave them a statement, you know, about who

was in there.

Of course, that had just happened.

I remembered everybody that was in the

place. I knew most all of them. I knew all

of them personally, even the black guy they

put in, Frank Holt, I knew him personally.

But as far as them asking me anything, no.

DEXTER KING: What was Holt

doing there? Do you know?

LOYD JOWERS: All I know is what

he told me. He was going to work at the

produce place. Damn, I can't remember the

name of it. It wasn't Frank Liberto's

place. It was the one over on Front Street.

LEWIS GARRISON: I can't think of

the name of it, either.

LOYD JOWERS: Well, Carter's,

that's where he worked.

DEXTER KING: Did the rifle

have a scope on it?

LOYD JOWERS: Oh, yes, sure

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

594

did. Clip-on kind.

LEWIS GARRISON: The problem

with wht Mr. Holt is saying, Mr. Jowers, is

they didn't operate at night over at the

produce company, did they?

LOYD JOWERS: To my knowledge,

they closed around five o'clock.

LEWIS GARRISON: I don't know

that he had anything to do with this case at

all.

LOYD JOWERS: I don't know,

either. Not really.

LEWIS GARRISON: There is

nothing to indicate that he ever had anything

to do with it at all. You never told anyone

he had anything to do with it?

LOYD JOWERS: All that detail

that come out on ABC was Willie Akins' idea.

ANDREW YOUNG: Was there

anybody black other than McCullough that was

in on the early planning?

LOYD JOWERS: Not that I know

of. There could have been.

ANDREW YOUNG: But he was the

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

595

only one that showed up in your place?

LOYD JOWERS: He is the only one

that ever showed up down there that had

anything to do with it. If there was any

more, if Jones was involved in it -- that was

Dr. King's driver. I knew him pretty well.

Is he still living?

DEXTER KING: People talk and

say they have seen him, but nobody has been

able to really pinpoint or locate him.

LOYD JOWERS: I hadn't seen him

in years. But I did know him.

LEWIS GARRISON: Last fall, a

year ago, Mr. Young, you've heard of an

Officer Redditt, an African-American, I had a

chance to talk to him a long time, and --

have you ever talked to him, Mr. King?

DEXTER KING: No, I haven't.

LEWIS GARRISON: He said that he

was there and, as you know, had been watching

Dr. King and I guess Mr. Young when they were

in Memphis, and he told me he was startled

because he had no knowledge of anyone ever

threatening him and had no reason to. The

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

596

first thing he knew, some officer came, I

forget the name of the officer, and got him

and took him to the police department, and

the police commissioner was there along with

who they identified as FBI agents and told

him that he had received a threat.

They took him to his home. An

officer went home with him to make sure he

stayed there. He said he knew what was going

on. By the time he got home, he heard about

the assassination. (Inaudible.) Strange

thing to me, though -- I've seen so many

strange things -- there is Mr. McCullough,

undoubtedly with the police department it has

been established, there he was, an

African-American on the scene, yet Officer

Redditt and the firemen, they were removed.

DEXTER KING: I think the point

you made was he was not interviewed as a

witness.

LEWIS GARRISON: Never. Not in

the police department or anywhere. His name

doesn't appear. He is shown in the pictures.

ANDREW YOUNG: Sam Donaldson was

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

597

the first one that pointed him out to me. He

said he was with Army intelligence and that

he was there to make sure that Dr. King was

dead.

LOYD JOWERS: Make sure Dr. King

was what?

ANDREW YOUNG: Was really dead.

DEXTER KING: He was checking

his pulse when he leaned over.

LEWIS GARRISON: I heard he was

supposed to give some type of a sign if he

wasn't.

(Reporter note: At this point

the tape ends and picks up with the following

statement by Mr. Jowers:)

LOYD JOWERS: Snub .38, a

short-shot .38. It was and snub nose.

That's four-inch of barrel. It shot a

projectile about that long. They called it a

short .38. They didn't make many of them. I

got it stolen from me.

LEWIS GARRISON: Mr. Jowers, you

told Mr. King, too, before what happened to

the casing of the bullet. What did you do

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

598

with that?

LOYD JOWERS: I put it down -- I

tried to bend it together. Well, I did bend

it together. I put it down in the commode

and flushed it. It didn't go down. It

stopped the damn commode up. Anyway -- this

is the next day. I got it out. That night,

whenever I closed, I drove across the

Mississippi bridge, and about in the center

of it I throwed it over the side while I was

driving along. It is in the bottom of the

Mississippi River, the actual shell, the

casing.

DEXTER KING: What time did

Lieutenant Clark -- what time did you see him

on April 4th? Like how many times or what

time did you see him in the grill? Was he in

before the actual shooting?

LOYD JOWERS: He had to be there

before ten o'clock, because I left there

about ten, ten-thirty.

DEXTER KING: That was in the

morning?

LOYD JOWERS: In the morning,

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

599

yeah.

DEXTER KING: What was he doing

there?

LOYD JOWERS: Pardon?

DEXTER KING: What was he doing

there?

LOYD JOWERS: He just stopped by

like the policemen used to always do.

ANDREW YOUNG: That was

Mr. Clark?

LOYD JOWERS: Yeah.

DEXTER KING: This is on April

4th?

LOYD JOWERS: This was on the

day of the assassination, yeah. I don't

think Johnny Barger come by that day, but I

know Clark did.

ANDREW YOUNG: But now Clark had

to come into the -- into your store and had

gone out through the back?

LOYD JOWERS: He didn't go all

the way to the back. You mean that

afternoon?

ANDREW YOUNG: That afternoon.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

600

LOYD JOWERS: It is a long brick

building.

ANDREW YOUNG: I know it.

LOYD JOWERS: It had an opening

over here. All he had to do was walk in

front of that fire station, walk on into

the -- no, he didn't have to come through my

place.

ANDREW YOUNG: What I was trying

to figure out is how did the rifle get out in

the backyard.

LOYD JOWERS: Clark had to carry

it out there, if he is in fact the one that

had it.

ANDREW YOUNG: So he carried it

from the back of your store?

LOYD JOWERS: Wait a minute. He

carried it from his car or a car. It could

have been a police car for all I know. I

wasn't back there. He carried it from the

street. Here is the fire station over here.

It ran around behind my store right around to

wherever it was he wanted to do the shooting

from, I guess.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

601

ANDREW YOUNG: But the box was

in your store on the day before?

LOYD JOWERS: The box had been

in my store, but I didn't give it to anyone.

That's what I'm telling you. I did not.

ANDREW YOUNG: Okay.

LOYD JOWERS: But now someone

picked it up. But I didn't give it to no

one. I couldn't swear it was a rifle. I

think it was. Which anyone -- you know, I

just didn't.

ANDREW YOUNG: But you are

pretty sure that when you were standing at

the back door, Clark gave you a smoking

rifle?

LOYD JOWERS: I'm sure it was

Clark.

ANDREW YOUNG: And then you put

it under the counter?

LOYD JOWERS: I broke it down

and put it under the counter. I breached

it. You know how you take the empty shell

out.

ANDREW YOUNG: Yeah.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

602

LOYD JOWERS: I broke it down

into two pieces, wrapped it in a table cloth,

put it up under the counter and put some more

towels on top of it. That's where it stayed

until the next day.

ANDREW YOUNG: And it was Raul

that came back and picked it up?

LOYD JOWERS: He didn't do

anything with it except left it wrapped in

that table cloth. He went out the front door

with it.

LEWIS GARRISON: What did he

tell you he came in for that day, Mr. Jowers?

LOYD JOWERS: What did who say?

Raul?

LEWIS GARRISON: Raul or Royal,

whatever --

LOYD JOWERS: He come to pick

that rifle up.

LEWIS GARRISON: Did he tell you

he came to pick the rifle up?

LOYD JOWERS: He asked me if I

had a package for him. I said, well, sure,

I've got it under the counter, I got it last

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

603

night. He said, that's what I'm asking for.

He was real short about it, like if

I wasn't going to give it to him, he'd blow

me away. Anyway, I give it to him, and

that's the last I seen of him.

DEXTER KING: Do you recall an

hour before the killing there was a phone

call made to Frank Liberto about -- in

Pepper's book they talk about this guy

McFerren overhearing a comment about "get the

SOB when he is on the balcony" or something

like that.

LOYD JOWERS: There was no phone

call that I know of made from my restaurant

whatever. I had a pay phone, but there was

not one made from my restaurant. If it

was --

DEXTER KING: You don't have

any idea who Liberto might have been speaking

with?

LOYD JOWERS: No, I do not.

Now, I had heard that, and I don't doubt it

taking place, but all I know is if somebody

made a phone call from my place, they would

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

604

have stepped inside and they called back

there while I was working. I was running

that place myself that night because I had no

help.

ANDREW YOUNG: Did you tell the

help to stay home?

LOYD JOWERS: No, sir.

ANDREW YOUNG: They just stayed

home accidentally?

LOYD JOWERS: I don't know if it

was accidental or not. I always wondered

about that, you know, because they were good

workers. Betty was a good worker, always

come to work.

ANDREW YOUNG: Is she still

alive?

LOYD JOWERS: Yes, she is still

alive. She lives in Memphis somewhere.

ANDREW YOUNG: Do you know where

she lives?

LEWIS GARRISON: She gave her

deposition.

LOYD JOWERS: She give a

deposition. She lives at 931 Roland.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

605

LEWIS GARRISON: I'm not sure.

Something like that.

LOYD JOWERS: That's where she

lives. I understand she either has sold the

house or done something with it and moved. I

have no idea where.

DEXTER KING: You mentioned a

pay phone. Where was it located?

LOYD JOWERS: Right in the front

of the building. There was a front door --

like there is a front door here. The pay

phone was between the front of the building

and my steam tables. Now, someone could have

stepped in and used that phone.

DEXTER KING: You don't

remember anybody --

LOYD JOWERS: I don't remember

seeing anybody.

DEXTER KING: -- about

four-thirty?

LOYD JOWERS: I sure don't.

That don't mean someone couldn't have stepped

in that door and used that phone and I never

would have known about it. Because I was

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

606

trying to wait on everybody in the place. I

think I had it full of customers, and I was

trying to wait on them.

DEXTER KING: Did you discuss

any of the details of what happened with any

of your associates, like Adkins (sic) or

anybody like that?

LOYD JOWERS: No. Willie said I

told him a lot of things, but he is a big old

liar. I ain't told him nothing. I'll tell

him that, too, if I ever see him again.

DEXTER KING: What time did you

come to work on the 4th, April the 4th?

LOYD JOWERS: Four o'clock.

That's the time I came every day unless --

LEWIS GARRISON: Four a.m.?

LOYD JOWERS: No, p.m. You was

talking about in the afternoon, wasn't you?

LEWIS GARRISON: He was talking

about in the morning. What time did you open

in the morning?

LOYD JOWERS: I opened at five.

I thought you meant that afternoon. I

already told you that I was home during the

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

607

day.

DEXTER KING: Right. Did you

come in on April 4th in the morning?

LOYD JOWERS: I was in there

that morning, oh, yeah, about four o'clock,

because I opened up at five.

DEXTER KING: What were you

saying about four, that you came in at --

LOYD JOWERS: That afternoon I

come in. See, after I got lunch ready, I

turned it over to my cook, and she handled

the lunch crowd. Then I come back to work

that afternoon at four o'clock.

DEXTER KING: What type of car

were you driving that day?

LOYD JOWERS: I don't know if I

was driving my station wagon or my Cadillac.

It was one or the other. Whichever one my

wife wasn't driving, I was driving the other

one.

DEXTER KING: Did you hear --

were you told that there would be --

actually, I read it -- that there would be

somebody in the organization, in Dr. King's

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

608

organization, that would get him on the

balcony, so to speak, or get him in the

position? Had you been told that?

LOYD JOWERS: To my

recollection, I don't remember anybody

telling me that, I do not. Now, that doesn't

mean they didn't do it. We're talking about

thirty years ago or longer.

DEXTER KING: Had you heard of

anybody on the inside that they had

infiltrateed or penetrated?

LOYD JOWERS: Sure, I heard

that. I sure did, from customers in the

restaurant. I heard plenty of it. How much

of that talk was true, I don't know. Maybe

none of it. I tend not to believe half of

it.

DEXTER KING: What kind of

stuff did you hear?

LOYD JOWERS: Well, I heard that

Jones was involved in it. Then I heard that

the other person I heard was -- it wouldn't

make sense to me, but the guy that took his

place, what's his name?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

609

ANDREW YOUNG: Ralph Abernathy?

LOYD JOWERS: Abernathy, yes. I

heard he had him moved from downstairs to

upstairs. I always doubted that. But

somebody had it done. It had to be someone

in his organization that would do it, I would

think, or his security. I always figured his

security had to have done it.

DEXTER KING: You never heard

anything mentioned about Reverend Kyles or

Reverend Jackson?

LOYD JOWERS: No, sir. I never

did. I never did. I heard a lot of good

about them. I never heard anything bad about

either of those men.

DEXTER KING: Did Liberto ever

mention his ties to Marcellous or -- what was

the guy in Memphis? -- Genovise or Venovise?

LOYD JOWERS: No, not that I can

remember.

DEXTER KING: But it was pretty

common knowledge that he was associated with

the Marcellous organization:

LOYD JOWERS: Oh, yeah. Half

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

610

the police department knew that. Or maybe

more than that.

LEWIS GARRISON: I believe you

are talking about prostitution, gambling and

what else?

LOYD JOWERS: Who you are

talking about?

LEWIS GARRISON: Mr. Liberto.

LOYD JOWERS: Oh, Frank? He

had a little gun-running deal, selling guns

to I guess the Cuban rebels, I guess, or at

least that is what I was told, you know.

LEWIS GARRISON: Gambling,

drugs?

LOYD JOWERS: Oh, yeah.

LEWIS GARRISON: Prostitution?

LOYD JOWERS: I would think that

money I handled for him before the

assassination, that that money was going to

buy drugs, guns, and payoff money. Now, he

had to pay off, I can tell you that.

LEWIS GARRISON: Who did he have

to pay off?

LOYD JOWERS: Well, he had the

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

611

police department in New Orleans, the police

department in Memphis. That got him a long

way. I'm not too sure he didn't pay

Mr. Crump some money back years ago. Because

he was one powerful dude in this town, you

can believe that.

DEXTER KING: Were there two

back doors from the building leading to the

brush area, one from the kitchen and the

other one from the rear stairway of the

rooming house?

LOYD JOWERS: Well now, are you

talking about where my restaurant was?

DEXTER KING: Yes, sir.

LOYD JOWERS: Okay. My

restaurant had a front entrance and it had a

back entrance. Okay. The upstairs had a

stairwell that come down the side, but it

stayed blocked off all the time. How they

got around the Fire Department blocking that

off, I do not know, but they did.

You could go down the steps, but you

get to that door and it would not open inside

or out. Of course, they had a front

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

612

entrance, and it went right down beside my

grill, which was inside the building, and it

went right out right next to my door.

My door was like here. Their

entrance was right here, just right around

the corner.

DEXTER KING: Do you know the

name of the people who were staying upstairs

in the rooming house --

LOYD JOWERS: Charlie Stephens.

DEXTER KING: -- on April 4th?

LOYD JOWERS: Charlie Stephens

is the only one I really knew. And the

crippled boy lived there. Damn, his name --

I'll be darn. I knew his name because he was

a customer that come in and bought a lot of

beer.

DEXTER KING: Was Earl Clark up

there or Raul that afternoon?

LOYD JOWERS: Not to my

knowledge. Not to my knowledge.

DEXTER KING: Do you remember

what Clark was wearing that afternoon?

LOYD JOWERS: No, I sure don't.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

613

He wasn't wearing a police uniform. I know

that.

DEXTER KING: I remember you

mentioning a white shirt I thought the last

time.

LOYD JOWERS: Are you talking

about the guy that handed me the gun?

DEXTER KING: Right.

LOYD JOWERS: Yeah, he had a

white shirt on. Sure did.

DEXTER KING: Do you remember

what else he may have had on?

LOYD JOWERS: Dark pants and a

white shirt. Other than that, I cannot tell

you, because it happened so fast, about like

that and he was gone.

DEXTER KING: Are you pretty

comfortable -- I should ask, did you see him

fire the shot, the rifle?

LOYD JOWERS: No, I did not. I

did not. I heard the shot when it went off.

I couldn't miss hearing it. Whether it went

off from upstairs or down in the bushes, I

couldn't miss hearing it. It sounded like a

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

614

damn cannon.

DEXTER KING: You say it did go

off upstairs?

LOYD JOWERS: Whichever place it

went off. There wasn't but how many feet up

there, ten, twelve feet. That was right over

my back door. That's where the bathroom is.

My back door is right here, and the bathroom

is about ten, twelve feet above.

DEXTER KING: But if he handed

you the rifle, how could he have been

upstairs?

LOYD JOWERS: He couldn't have

been. Now, how you explain that and the test

shows that that bullet was going down, there

is only one explanation for it, and two or

three different people have said this

happened. Jones said something to him about

getting his overcoat or a coat, and he bent

over the counter -- this is the only

explanation I can come up with. He bent over

the rail. That's when he got shot on the

balcony.

DEXTER KING: From down in the

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

615

bushes?

LOYD JOWERS: Yeah.

ANDREW YOUNG: Your place was on

a hill, though.

LOYD JOWERS: Yeah.

ANDREW YOUNG: So the bushes and

the room were about the same level?

LOYD JOWERS: They were about

the same level. You see, if you shoot a

rifle --

ANDREW YOUNG: He was sort of

like that, leaning over talking.

LOYD JOWERS: He was leaning

over trying to hear what Jones was talking

about. That has to be the only explanation.

It went in long about here.

ANDREW YOUNG: It hit the tip

of his chin.

LOYD JOWERS: Oh, it did? It

did hit his chin? Okay.

ANDREW YOUNG: And then --

LOYD JOWERS: So he had to be

leaning over that railing. Now, if he in

fact was shot from there, from that backyard,

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

616

then that's where it had to be. I would say

it would be a pretty good angle from up in

that rooming house. Whether that is the way

it happened, I don't know. That's the only

explanation I have for it.

LEWIS GARRISON: Was the door to

the basement open that afternoon?

LOYD JOWERS: I never locked

it. There wasn't nothing down there. I

figured there was no reason to lock it.

There sure wasn't.

DEXTER KING: Do you know

whether Clark or anybody went down there

after the shooting?

LOYD JOWERS: I have no idea.

DEXTER KING: Do you think

Clark put on a uniform or had a uniform after

the shooting?

LOYD JOWERS: I have no idea.

DEXTER KING: But if he had on

a white shirt, would it have been easy for

him to change into other clothes?

LOYD JOWERS: He could change

shirts in a matter of seconds if you didn't

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

617

have it already buttoned up. Sure you

could. He could have changed that when he

got in the car.

DEXTER KING: So you never saw

him anymore after that?

LOYD JOWERS: No.

DEXTER KING: Who was in the

brush area at the time of the shooting?

LOYD JOWERS: I have no idea.

DEXTER KING: So you took the

rifle and just went inside?

LOYD JOWERS: I was already

inside. He handed me the rifle through the

back door.

DEXTER KING: He just came into

the back door or to the back door?

LOYD JOWERS: He was about from

here to Junior there. He didn't have to hand

me the rifle. He threw it to me. He threw

it to me like you would do a soldier. Of

course, I caught it. It had just been

fired. I heard it when it went off. I done

what Frank told me to, I broke it down and

put it under the counter and went on and

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

618

waited on my customers.

DEXTER KING: Did you see

anybody driving the Mustang that afternoon, a

white Mustang?

LOYD JOWERS: I did not. I know

there was one parked in my parking place when

I got to work at four o'clock. I pulled

right up behind him like that.

DEXTER KING: That was on South

Main?

LOYD JOWERS: On South Main. I

did notice it had out-of-state tags, but I

don't know what state it was. I knew it

wasn't local. I figured it was shoppers over

across the street over there shopping.

That's what I figured. I got as far away

from that sparkplug (sic) as I could and got

on out and went to work.

DEXTER KING: In your opinion,

and I know it is just an opinion, do you

think Earl Clark was the trigger man?

LOYD JOWERS: Now, you know, I

have an opinion of that. Now, my personal

opinion, I think he was. I sure do.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

619

DEXTER KING: Why do you --

aside from him throwing you a rifle, was

there any conversation you all had beforehand

or any talk you had heard about did he have a

reason to or was it just money? Why would he

have done it? What was his motive, I guess?

LOYD JOWERS: I would think

probably for money. That's what I would

think. That's what I believed at the time.

ANDREW YOUNG: Somebody -- was

there any evidence that he lived a little

better after the shooting?

LOYD JOWERS: I really don't

know, Mr. Young.

ANDREW YOUNG: You didn't see

him anymore?

LOYD JOWERS: If I ever seen

that man any more up until -- he is dead,

isn't he?

LEWIS GARRISON: I think he has

died.

LOYD JOWERS: I don't remember.

I don't think I ever seen him anymore.

LEWIS GARRISON: Even though you

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

620

had been a close friend and had been hunting

companions?

LOYD JOWERS: Oh, yeah, we had

been friends for years.

DEXTER KING: What about do you

recall which police officers interviewed you

after the shooting?

LOYD JOWERS: I have no idea.

They really didn't do any interviewing that

night. They took down a name and address and

telephone number and told us to go home when

they got all the information, name, address

and telephone number. That's all I give them

that night.

DEXTER KING: Who conducted the

crime scene I guess interrogation? Was it

FBI or the Memphis police?

LOYD JOWERS: I have no idea.

DEXTER KING: What about the

people, Barger -- is it Barger or Barjer?

LOYD JOWERS: Barger,

B A R G E R.

DEXTER KING: Zachery,

McCullough, Clark, Liberto, did you see any

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

621

of those people after the killing?

LOYD JOWERS: You mean that

night?

DEXTER KING: Right.

LOYD JOWERS: Or the next day?

No, sir.

DEXTER KING: Or even the next

day. I know you talked to Liberto.

LOYD JOWERS: I talked to

Liberto. I didn't see him. I didn't see

none of them the next day. I sure didn't.

DEXTER KING: How many times

did you meet McCullough?

LOYD JOWERS: As far as actually

meeting him, like you telling me his your

name is McCullough and me telling him my

name, I don't think I ever did. I did know

him. I knew him when I seen him and still

would, I think, even though it has been

thirty years.

DEXTER KING: How deep do you

think he was involved in the killing?

LOYD JOWERS: I don't really --

really and truly? I think he was just

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

622

following orders. That's exactly what I

think. I always believed that. I believed

he was just doing what he was supposed to be

doing.

DEXTER KING: How many planning

sessions did you see him attend?

LOYD JOWERS: How many what?

DEXTER KING: How many planning

sessions did you see him attend?

LOYD JOWERS: Just that one time

when he come in the grill. I had no idea

what they were talking about. I got a word

here or there. I knew it was illegal,

whatever it was. It wasn't unusual.

DEXTER KING: And Barger

brought him in?

LOYD JOWERS: I didn't say --

DEXTER KING: Did he work for

Barger?

LOYD JOWERS: See, Barger was a

field inspector.

DEXTER KING: What does that

mean? He was over the uniformed division?

LOYD JOWERS: He was over a

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

623

section of the uniformed. They had four

field inspectors. I don't know how many

policemen worked on each section. If I had

to guess, I'd say about a hundred, maybe a

hundred twenty-five.

Of course, they had the city split

up. Each one of them had -- I believe they

call them assistant chiefs now, but they were

field inspectors back then.

DEXTER KING: How much money

was Clark paid?

LOYD JOWERS: I have no idea. I

don't have the slightest idea.

DEXTER KING: What do you -- who

do you think paid him, then?

LOYD JOWERS: The man who said

his name was Raul. He is the one I gave the

money to. He had to be the one who paid him.

DEXTER KING: Do you think that

Raul approached Clark about being the

trigger man?

LOYD JOWERS: I don't know. I

wouldn't doubt it, but I don't know.

DEXTER KING: Do you know of

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

624

any other Memphis police officers that would

have received money for the operation?

LOYD JOWERS: No, I do not. I

don't know that Clark got any money out of

it. I just know I believe he did. But as

far as I seen him getting any, he may have

done it for the fun of it. I don't know.

You never know about people.

DEXTER KING: Did you ever hear

anything about this hoax radio broadcast, you

know, that this broadcast was put out over

the police radio that the suspect was

traveling in one direction?

LOYD JOWERS: Oh, yeah, I heard

about that. He was supposed to have been out

in Raleigh or somewhere like that, a white

Mustang, the police were supposed to have

been behind him, and James Earl Ray said he

was going the other direction going down 65.

DEXTER KING: Going north?

Going north or south.

LEWIS GARRISON: South.

DEXTER KING: South, rather.

But the radio said he was going north?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

625

LOYD JOWERS: Going north, yeah.

DEXTER KING: Now, it has been

said the only people who would have had the

technology to break into police radio

frequency would have been the military.

LOYD JOWERS: They are wrong

about that. I had a scanner that picked

up -- I think they had four channels. I had

a scanner that picked up all four of those

channels.

DEXTER KING: No, no, not pick

up but to actually break in and broadcast.

LOYD JOWERS: Oh, yeah, to

break in and talk on it, that would be the

military.

DEXTER KING: In fact, that

came out in the House Select when they did

their investigation.

LOYD JOWERS: I misunderstood

you.

DEXTER KING: Sure.

LOYD JOWERS: I thought you

said --

DEXTER KING: To listen. You

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

626

can monitor. But to actually break in and

broadcast.

LOYD JOWERS: Yeah.

DEXTER KING: What about the

taxi driver that picked up the passenger at

the time of the killing and said they saw a

man who came down over the wall and get into

a Memphis police car up on I think Huling?

Is it Huling Street?

LOYD JOWERS: Huling, yeah.

DEXTER KING: And the driver

was killed that night.

LEWIS GARRISON: I don't think

he knows anything about that. What happened

with that was after this Prime Time telecast,

there was a gentleman that called me and gave

his name to Dr. Pepper, like he states in his

book.

The statement he made was that he

was a cab driver that night and that a friend

of his was also a cab driver and that this

friend was over at the Lorraine Motel and

radioed him and said I just saw -- well, he

said he was unloading some luggage and that

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

627

he was looking up and recognized Dr. King,

and he said -- he radioed to his friend that

"I just saw Dr. King was shot."

He said he called his dispatcher,

and he told him to go ahead and get out of

the area. So the gentleman called me who is

still living in Memphis and said that he told

his friend to meet him out at the airport at

a place they frequent out there.

He said two officers came out

there. He heard his friend give the police

officer an account of what he had saw. He

had seen just what you said, someone who ran

and got in a police car.

Then he'll tell you this today -- he

has talked to several people. But at any

rate, he said the police officer said, okay,

come down in the morning to the station and

give us a full statement. So the next

morning they found the man's body across the

bridge on the Arkansas side and they said he

had been thrown out of a car.

LOYD JOWERS: I remember that

cab driver getting killed. I didn't know

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

628

about all that.

LEWIS GARRISON: But there is no

account of it. You can't find a thing about

this. But this man will tell you that

today. I gave his name to Dr. Pepper.

ANDREW YOUNG: Do you remember

his name?

LEWIS GARRISON: No, sir, I

don't have it here with me right now.

DEXTER KING: This is actually

in Pepper's book, the name of the fellow?

LEWIS GARRISON: Yes. He gave

Dr. Pepper his name.

LOYD JOWERS: I didn't know

anything about it.

LEWIS GARRISON: I've had

someone interview him before Dr. Pepper did.

That's exactly what happened. Louis Ward, I

believe it is something like that.

DEXTER KING: You believe they

just got rid of the file?

LEWIS GARRISON: I think there

is no question. After we began to dig into

it, we could find no record where the man was

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

629

even killed. I believe his name is

Mr. Ward. He will tell you today that's what

happened.

He said he heard the man at the

airport tell the two police officers that he

had seen Dr. King -- he was unloading

luggage, looked up and saw Dr. King over the

railing, and he said he saw him -- it looked

to him like it blowed his whole face off. He

looked around immediately and saw a man

running and get into a police car.

Then he radioed his dispatcher. Of

course, he said they were close friends.

This man said he was out in East Memphis. He

said, well, let's meet at the airport and

we'll talk about it. He said two police

officers came out there and interviewed the

man.

He said, I heard him give the

statement, tell the police exactly what he

had seen. They said to come in in the

morning and give a full statement at the

police station. But then he was found dead

on the Arkansas side. The story was someone

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

630

threw him out of a car.

But we can't find even a trace of

it. In fact, the cab company claims they

can't find a company record that he even

worked there. We went so far to check with

the cab company. They couldn't find

anything. They won't admit it.

DEXTER KING: What did you hear

was learned about any prior knowledge about

the killing or involvement of anybody with a

public or private person in Memphis or

elsewhere or any state officials or federal

officials?

LOYD JOWERS: Any knowledge I

had prior to the assassination?

DEXTER KING: Uh-huh. Or even

after.

LOYD JOWERS: I heard everything

in the world I guess after. But I didn't put

much stock in it. Most of it was just beer

talk, you know.

DEXTER KING: Anything before?

LOYD JOWERS: Never heard a

thing before.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

631

DEXTER KING: You mentioned

Solomon Jones. But you heard that after.

That is beer talk, is that what you mean when

you you said beer talk, the thing you said

about Solomon Jones?

LOYD JOWERS: Oh, yeah, I heard

that afterwards, that he was talking to Dr.

King up on the balcony. If he in fact was

shot from my backyard, Dr. King would had to

have been leaning over that balcony. He

would have had to have been. Otherwise that

bullet could have gone up. I mean, it was

that or it would have gone level.

ANDREW YOUNG: It could have

gone either way. It really -- you can't tell

which way it went because it was such a clean

wound that --

LOYD JOWERS: Didn't it hit a

bone in his --

ANDREW YOUNG: A bone in his

spinal cord. I don't think it hit anything

in his shoulder.

LOYD JOWERS: I thought it hit

his collar bone.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

632

LEWIS GARRISON: I don't think

so.

ANDREW YOUNG: The collar bone

is up here.

LOYD JOWERS: That's what I'm

talking about. It was like from here to here

just blown away.

LOYD JOWERS: Yeah.

DEXTER KING: Now, Mr. Jowers,

when we met the last time, it was clear that

we felt we needed to meet again to really

get --

LOYD JOWERS: Oh, yeah.

DEXTER KING: -- get more

detail. I'm trying to remember, and I'm

going off the top of my head, what you had

stated today that you haven't already stated,

and I can't really seem to pinpoint anything

much different than what you already said

then.

I wanted to just ask for your -- if

you could help me here, because I'm trying to

recall was there something that I missed the

last time that you stated today that you

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

633

didn't state before.

LOYD JOWERS: The only

difference is that I'm almost positive it was

Clark in my back door, and I'm not sure about

the rifle. But I'll tell you what I

thought. I thought it was a 30-30. It could

have been a 30-06, as well as it could have

been a 30-30.

Now, when the shot went off, it

sounded like a 30-30, because they are a lot

louder than a 30-06 when they are fired.

That is two things. The other -- I told you

something else that I didn't tell you

before. I don't know what it was. It is on

that tape, of course.

DEXTER KING: Well, is there

anything you want to tell me that I haven't

asked that you think might be helpful?

LOYD JOWERS: I can't think of a

thing, Dexter. Now, I've told you up to now

everything I know about it.

DEXTER KING: What have you --

or from your opinion or what you have heard,

rumors included, at what level of government

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

634

or involvement do you think this

assassination was carried out by plan?

LOYD JOWERS: What you want to

know is where the order come from?

DEXTER KING: Right.

LOYD JOWERS: It is my opinion

and my belief that the order come from J.

Edgar Hoover. Now, that's where the order

come from.

How to prove that, there is no way.

I could just easily said the President, but I

know better than that, because I don't

believe the president would have done that.

But now J. Edgar Hoover hated your dad.

DEXTER KING: How could -- if

military were involved, wouldn't the

Commander in Chief by just from you being in

the service and knowing --

LOYD JOWERS: Well now, wait a

minute now. The CIA or FBI are not

military. No.

DEXTER KING: No, I'm

saying --

LOYD JOWERS: You mean if the

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

635

military was involved?

DEXTER KING: Right.

LOYD JOWERS: Yeah. Not only

that, but there would be a record of it.

DEXTER KING: And wouldn't the

Commander in Chief have to give the order if

they were involved in something like that?

LOYD JOWERS: Some word between

the guy that was doing the assassination and

the President, somebody in between there

would give the order. But first it would

have to come from the head honcho.

ANDREW YOUNG: Hoover had a man

who was his number two man who was almost

staying in the White House, Lee DeLoach. He

was the one that was keeping -- that was sort

of telling Lyndon Johnson what they wanted

him to know.

LOYD JOWERS: Yeah.

DEXTER KING: Let me also ask

you is there anyone that you know of that can

present scientific evidence about this case,

anything that occurred that you know of,

somebody who is still living that would

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

636

have -- that would be able to say not only

did I see this, here is evidence, a rifle or,

you know, anything concrete?

LOYD JOWERS: To my knowledge, I

don't know of anyone that has scientific

evidence of which rifle did actually kill

him. I definitely don't believe it was the

one the police found. I'll never believe

that in a million years.

ANDREW YOUNG: Where did they

find that?

LOYD JOWERS: Right in front

of -- see, this was the street here and the

sidewalk. My building was right here.

You've got the rooming house, two doors here,

two rooming house doors, then you've got an

amusement company over here. His front door

sits back I guess it must be ten feet.

That's where the rifle was found.

DEXTER KING: So it is your

feeling that James Earl Ray did not --

LOYD JOWERS: No. He didn't no

more kill him than you killed your own dad.

No. No. Nope. I'd never believe that in a

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

637

million -- even if he told me I wouldn't

believe it.

DEXTER KING: So why was he set

up?

LOYD JOWERS: His own fault.

They got him out of jail. They furnished him

money. They furnished him passports. Now,

they come up with that tale about him setting

up a gun deal, but that wasn't true. They

may have told him that, you know.

But now he stalked your father

halfway across the United States, went to

Atlanta, had all that written down. Now, he

was doing that for the CIA and the Mafia.

That's exactly why he was doing that.

DEXTER KING: What if they told

him to go to these places so they could

establish a paper trail with established

documentation? If they were in fact using

him as a set-up person, wouldn't they want

him to appear that he was stalking him?

LOYD JOWERS: Why, certainly

they would. Sure they would.

DEXTER KING: So is it possible

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

638

that he was doing things that appeared to be

stalking but maybe he didn't realize it?

LOYD JOWERS: He probably didn't

even realize it, yeah. Yeah. I'm sure

that's the way it went down. I'm sure.

Because if he wasn't going to -- if he had no

intention of hurting Dr. King, which I don't

believe he did, why would he want to be

stalking him?

He was doing what he was told to

do. That was to make it look like that he

was stalking Dr. King, whether he was or

not.

DEXTER KING: Well, I think I

have asked --

ANDREW YOUNG: Do you mind me

taking a picture of this?

LOYD JOWERS: No, no. We'll

make you a tape of that, if you want to.

Help yourself. Go right ahead.

ANDREW YOUNG: Why don't you

lean toward --

LOYD JOWERS: Can you see all of

us?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

639

ANDREW YOUNG: Yeah, I can.

LOYD JOWERS: Do you want me

to -- do you want to take some pictures for

your family?

DEXTER KING: Sure.

LOYD JOWERS: Do you want me to

smile or not? Okay, I was just kidding.

DEXTER KING: Do you want me to

snap you?

LOYD JOWERS: Well, Dexter, I

wish I knew exactly who done the killing, but

I don't. If I did, believe me, I'd say it.

But I do know this for sure: It was a

for-sure conspiracy.

LEWIS GARRISON: Well,

Mr. Jowers, isn't it true that Mr. Young and

Mr. King --

LOYD JOWERS: Lewis, I can't

hear you.

LEWIS GARRISON: Isn't it really

true that Mr. -- that lieutenant Clark did

it? You know that, don't you?

LOYD JOWERS: I'm almost

positive. But as far as seeing his face, I

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

640

did not.

LEWIS GARRISON: But he had on

the clothes and all that you had seen him in

earlier?

LOYD JOWERS: Yeah, I had seen

him in the same clothes. But as far as me

seeing his face, I did not. Now, I saw the

back of his head.

ANDREW YOUNG: The people who

were involved in this as far as you know that

are still alive would be --

LEWIS GARRISON: Lieutenant

Zachery.

LOYD JOWERS: Zachery is still

alive.

LEWIS GARRISON: McCullough.

McCullough is still alive.

LOYD JOWERS: McCullough.

LEWIS GARRISON: Who else? Of

course, Mr. Jowers. Ms. Spates in front of

Mr. Jowers -- he knows because he was

there -- she says what he saw.

LOYD JOWERS: That was a big old

lie.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

641

LEWIS GARRISON: You know she

described it in lengthy statements under oath

that she saw this.

LOYD JOWERS: Oh, yeah, sure.

LEWIS GARRISON: You heard that

under oath, heard her say that?

LOYD JOWERS: Sure, I was right

there.

LEWIS GARRISON: She had given

the deposition. She gave affidavit after

affidavit and described what she saw. You

know, that don't you?

LOYD JOWERS: Yeah.

DEXTER KING: That's what I

don't understand. How would she -- why would

she go to that extent?

LOYD JOWERS: To get at me.

DEXTER KING: What?

LOYD JOWERS: That's why. No

other reason. She is really and truly -- she

is serious about that, too. There is not a

dad-gum word of it that is true, but she

believes it, and there is nobody that can

change her mind, that I actually done the

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

642

shooting.

DEXTER KING: Oh, she thinks

you did the shooting?

LOYD JOWERS: Damn right she

said it. I don't know if she said it in the

deposition or not, but she told me that.

DEXTER KING: Now, how many

times did you see Clark that day in your

grill?

LOYD JOWERS: One time.

DEXTER KING: That was in the

morning?

LOYD JOWERS: That don't mean he

wasn't in there more than that. See, I left

about ten, somewhere around ten.

DEXTER KING: You said

Ms. Spates used to be your girlfriend?

LOYD JOWERS: Yes, sir.

ANDREW YOUNG: Hell hath no

fury like a woman scorned.

LOYD JOWERS: And, buddy, she

got one hell of a temper, too.

LEWIS GARRISON: She has two

children and says he is the father.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

643

LOYD JOWERS: I offered to go

with her to take a blood test. Then we'll

find out if I am or not. She backed out.

Right on up to the time to go, then she

backed out. She knew damn well I wasn't the

father of those children. If I had been, I

would have been supporting them.

LEWIS GARRISON: Mr. Jowers,

under oath, though, you said you were engaged

in a sexual relationship with her?

LOYD JOWERS: Well, hell, yeah,

for some period of time.

LEWIS GARRISON: That went on

for a year or two?

LOYD JOWERS: It was longer than

that, more like five years.

LEWIS GARRISON: I several

years?

LOYD JOWERS: Like I say about

the President, a man is allowed to do any

damn thing, you know, especially a lounge

man.

LEWIS GARRISON: Why don't you

step outside a moment and let me talk to

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

644

them.

LOYD JOWERS: Okay.

ANDREW YOUNG: We really

appreciate your seeing us, your coming

forward.

LOYD JOWERS: I hate I'm not any

more help now. If there is anything I can

do, you can believe I'll do it.

DEXTER KING: You said if you

thought it would help, you would come

forward --

LOYD JOWERS: Yeah.

DEXTER KING: -- to the media?

Don't you think it would cause people to

start --

LOYD JOWERS: I think it would

get me put in jail. I think it would get me

indicted. That's exactly what I think. I

could be wrong, but I don't think so.

DEXTER KING: Okay.

ANDREW YOUNG: Thank you very

much.

LOYD JOWERS: See you later.

ANDREW YOUNG: Okay."

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

645

(This is the end of the tape

proceedings played in the court room.)

THE COURT: All right, ladies

and gentlemen. This is a good time for us to

break for lunch.

(Jury out.)

(Lunch recess.)

THE COURT: All right. Bring

the jury out, please, sir.

(Jury in).

THE COURT: All right, Mr.

Pepper. You may proceed.

MR. PEPPER: Your Honor,

plaintiffs call His Honor Judge Arthur

Haynes.

ARTHUR J. HAYNES, JR.

Having been first duly sworn, was examined

and testified as follows:

DIRECT EXAMINATION

BY MR. PEPPER:

Q. Good afternoon, Judge Haynes.

A. Good afternoon, sir.

Q. Thank you very much for joining us

here this afternoon: Would you state for the

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

646

record, your full name and address.

A. Arthur Jackson Haynes, Jr., 3533

Spring Valley Terrace, Birmingham, Alabama.

Q. And what is your present occupation?

A. I'm a circuit judge, Tenth Judicial

Circuit, Birmingham, Alabama.

Q. How long have you been a circuit

court judge?

A. Fifteen years.

Q. And before you were a circuit court

judge, what did you do?

A. I was a lawyer, a courtroom lawyer.

Q. You were a trial lawyer?

A. Yes, sir.

Q. Was there a time in 1968 that you

were asked to become involved in the case of

the assassination of Martin Luther King, Jr.?

A. I was.

Q. And what was the position that you

undertook at that time?

A. Well, simple arithmetic will tell you

I was a very young lawyer at the time. James

Earl Ray contacted my father, who was also a

trial lawyer. We had had some success in

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

647

defending highly-publicized difficult,

unpopular cases.

When James Earl Ray was arrested in

London and contacted us, asked us to

undertake his representation. Actually, we

were contacted by R. J. Sneyed, which was the

name he was traveling under on a Canadian

passport. We went to London.

Q. You and your father then became

defense lawyers for James Earl Ray?

A. Yes, sir.

Q. You were his first defense lawyers.

Is that right?

A. Yes, sir.

Q. And did you undertake the trial

preparation of that case?

A. Absolutely.

Q. And were you ready to go to trial?

A. Yes, sir. Absolutely. He changed

lawyers the night before I was going to give

the opening statement in the case.

Q. You were prepared to go to trial

right up to the night before the trial date

and then what happened?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

648

A. I left James Earl Ray on Friday. I

spent all day with him here in Memphis on

Friday getting ready for trial. I returned

to Birmingham late Friday evening and came

back on Sunday night. I had to get new

suits, do some final things to get ready for

trial. When we arrived, we were handed a

note saying that when changed lawyers.

Q. Were you able to eventually learn

what happened and why he made that change of

counsel at the midnight hour?

A. I never did know for sure, Mr.

Pepper. That remains a mystery to me. I

know that he contacted us approximately one

week later and said, gentlemen, I made the

biggest mistake I ever made, would you please

come back to try this case for me, all this

new fellow wanted me to do is plead guilty.

Q. It was too late by then?

A. Yes, sir. The case was so bolloxed

up that we just weren't willing to get back

involved in it.

Q. Judge Haynes, since you took that

case up to the eve of trial and diligently

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

649

prepared the trial, you were very familiar

with the evidence that the State had?

A. Yes, sir.

Q. We're going to talk about a

particular aspect of that evidence here this

afternoon, but in general what is your view,

what can you tell us now in terms of how you

saw the case?

A. In 1968 on the eve of trial the State

was absolutely confined to a theory of one

man: James Earl Ray, acting alone, killed

Dr. King. Our view of it was that the

evidence and testimony was inescapable that

that was an impossible result both factually

and it was an impossible result at the

trial. We were absolutely confident that the

case would be won.

Q. Were you and your father not in fact

asked to take a plea bargain to James Earl

Ray offered by the State early on because

they didn't want to try this case?

A. I don't know what they wanted to do,

but, yes, we had a plea bargain offered

earlier and took it to James Earl Ray.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

650

Q. What were were the terms of that plea

bargain, do you recall?

A. I've forgot exactly what they were,

Mr. Pepper. Whatever the plea was, the plea

we were offered allowed for parole in ten

years. I believe he took a ninety-nine year

sentence, which at that time made him

eligible for parole in thirty-three years.

And we were offered a sentence that allowed

for parole in ten years. Of course, parole

wasn't a likelihood in that case, anyway.

The offer was better than the one we had, at

least theoretically.

Q. What was James Earl Ray's response to

that offer?

A. It was preposterous. Neither he nor

we were going to consider a plea of guilty in

a case that should have been won. Obviously

we would have considered a reasonable plea,

but I think the circumstances were such that

a lesser plea simply was not something that

the prosecutors were putting forward.

Q. Okay. Moving on, you and your father

and your team of investigators obviously

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

651

interviewed a good number of witnesses.

A. Yes, sir.

Q. Did you do some of this interviewing

yourself personally?

A. Yes, I did.

Q. And did you at one time or another

interview a man called Canipe, who owned a

store on South Main Street?

A. Sure. Canipe Amusement Company, yes,

sir. We interviewed Mr. Canipe.

Q. So that we can set the location of

that, Judge, if I can bring you back to an

area which I'm sure you haven't thought about

in many years, but --

A. I recognize it vividly.

Q. This, you see, is a depiction of the

rooming house --

A. Yes, sir.

Q. -- which it had two wings?

A. Right.

Q. And underneath one wing do you see

roughly where Canipe's store would have been?

A. Put your pointer right back where it

was. I believe there was a doorway to the

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

652

rooming house there and then to the right

there was an angle doorway. If you would cut

off that corner roughly there was an angled

entranceway to the Canipe Amusement Company.

It would be in the lower right-hand portion

of that building where you are pointing,

right about where your pointer is.

Q. That's where Canipe's Amusement

Parlor was located?

A. Yes.

Q. Now let's put up a couple of

photographs. Does that look familiar?

A. Yes, sir.

Q. This is the amusement company you are

speaking about?

A. Right. That's the angled

entranceway.

Q. That's the angled entrance here?

A. Yes.

Q. This is the entrance -- one of the

entrances to the rooming house.

A. Yes, sir.

Q. The other entrance is right over here

between the two wings of the rooming house.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

653

Q. There was a -- on the second floor --

I never went out that entrance, but there was

a crosswalk used by anyone that went in that

entrance there. There was another entrance

there or around the back, one, I forget

which.

Q. Right. Now, what was the State's

contention with respect to evidence that was

found in this area?

A. The State's theory was there was a

Browning box, a Browning rifle box, that

contained some items of clothing, a radio

that had James Earl Ray's Missouri state

penitentiary number on it and a Remmington

760 rifle that James Earl Ray had bought in

Birmingham. That box was -- I believe the

rifle itself was wrapped in clothing. I'm

not totally sure of that. The box itself was

wrapped and tied in some fashion.

The State's theory was that James

Earl Ray had fired the shot that killed Dr.

King, had run across the entranceway there in

that slant between the two buildings.

Adjoining these two buildings was sort of a

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

654

rickety metal connecting-way. The State's

theory this was James Earl Ray had fired the

shot from the bathroom on that second floor,

come down that hallway into his room and

carefully packed that box, tied it up, then

had proceeded across the walkway the length

of the building to the back where that stair

from that door came up, had come down the

stairs out the door, placed the Browning box

containing the rifle and the radio there in

the Canipe entryway.

That was the State's theory. It was

the only theory that they could have with

James Earl Ray acting alone in order to prove

their theory.

Q. Then he proceeded to get into a

Mustang and drive away?

A. That's right.

Q. The Mustang was supposedly parked

somewhere around here.

Would you put on the second

photograph. Now, that's a closer view of the

angled doorway. Where did they say this

evidence box was --

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

655

A. I've never seen that picture,

Mr. Pepper. I believe the evidence box was

to the right sort of up against that brick

wall to the right, I believe.

Q. Right here?

A. Yes.

Q. We're talking about thirty-one,

thirty-two years ago. I believe that's where

it was. Mr. Canipe, who owned that amusement

company, was on the scene at the time of the

killing. Is that right?

A. That's what they told me, yes, sir.

Q. Did you have an opportunity to

interview him?

A. Yes.

Q. How long after the actual event do

you recall that you interviewed him?

A. How long after the event was it when

we interviewed him?

Q. Yes.

A. Dr. King was killed April the 4th.

James Earl Ray was arrested in June. He

contacted us immediately. We started

investigating it immediately, even before we

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

656

went to London. I would say it was in the

August range, July, August of 1968.

Q. The summer of 1968?

A. I'd say so, yes, sir.

Q. That was at a time when the events

would have been fresh in the mind of Mr.

Canipe?

A. Of course, I don't know what was --

here I am being a judge. I'm sustaining the

objection. I don't know what was in his

mind, but it should have been fresh. It was

immediate.

Q. When you spoke with him, did he

appear to be aware of --

A. Absolutely, sure. He remembered it

very vividly. In fact, we turned over that

entire area, as you can, imagine looking for

not only witnesses but also to exclude people

who later may or may not have knowledge about

it.

He was one of the more reliable

people truthfully that we found down there.

Those in Dr. King's party, they were not

aware of what was happening, as they were on

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

657

the other side of the street.

Q. What did he tell you -- precisely

what did he tell you about what he recalled

about the dropping of that evidence?

A. He said that the package was dropped

in his doorway by a man who dropped it in his

doorway and headed down South Main Street,

headed south down Main Street on foot, and

that this happened at about ten minutes

before the shot was fired. He was tied up

doing something but saw it happen and didn't

go out to check what it was.

Q. He told you that this bundle of

evidence was dropped in his doorway about ten

minutes before the shot was actually fired?

A. Yes, sir.

Q. What did you think of that?

A. We thought it was terrific evidence.

Furthermore, it was very credible, because

right next to that was a fire station, and

the fire station was packed with Memphis

Tactical Squad detectives, firemen, curiosity

seekers, people who were security for Dr.

King and also surveilling him. The fire

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

658

station was packed with people looking out

the back.

Of course, when they saw Dr. King go

down, the fire station erupted like a

beehive, and they poured out down the

driveway out the door coming looking both in

the bushes, where most of them thought the

shot was fired, and also on down on Main

Street.

So to us it is circumstantial. In

addition to the time involved, it was

circumstantially almost impossible to believe

that somebody had been able to throw that

down and leave right in the face of that

erupting fire station.

Not only was Mr. Canipe a credible

witness, but what he said was very credible

taking into account all the circumstances.

We were very very impressed with his

testimony.

Q. Judge Haynes, at this point in the

plaintiffs' case we're dealing with the

rifle, the rifle in evidence.

A. Yes, sir.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

659

Q. And the death slug. Was the rifle

that was found in that box the weapon that

the State contended was the murder weapon?

A. It was. It was the only weapon

found.

Q. Were you familiar at that time with

any ballistics testing of that weapon?

A. Yes, sir, from the FBI lab. Of

course, they took it to Washington and

performed ballistics tests.

Q. What were the results of that testing

that was done at the time?

A. I believe the phraseology used in the

report was that the evidence slug, that is,

the slug taken from Dr. King's body, and the

rifle, that the evidence slug was consistent

with the type of slug fired by that rifle.

In essence, the best they could do was that

Dr. King was killed by a 30-06 rifle and that

this was a 30-06 rifle.

Q. That's all they could say. Could

they match the bullet, the death slug itself,

to that rifle?

A. We didn't think they had a chance in

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

660

the world of matching it. As the FBI -- if

there is a match, if they can make a match

out of a little piece of a slug the size of

your little fingernail, if they did, the

testimony would be that the evidence weapon

to the exclusion of all other weapons in the

world fired the evidence slug. No, sir, they

could not do that.

Q. But is there any doubt in your mind

that if they could have matched that death

slug they took from Dr. King's body to that

rifle in evidence, that they would have done

so?

A. There is no doubt about that. They

would have prized that testimony. That would

be crucial testimony. Then you wouldn't have

to rely on any of the vagaries of eyewitness

testimony. Sure, that would be very

important testimony. Well, we thought it was

important.

Q. Now, did there come a time in the

course of your investigation when you

actually yourself saw, held, examined

personally the death slug?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

661

A. Yes, sir. I held the slug that

killed Dr. King in my hand.

Q. Had you seen other death shrugs and

other bullets at that point in your career?

A. Yes, sir.

Q. What was your view with respect to

that particular slug that you examined at the

time?

A. To the naked eye, it was as good an

evidence slug as you can have. It was a

Remmington core lot bullet and it had a metal

base to the slug. The metal base wasn't

skewed. It was almost perfectly round. See

could the lands and grooves, the marks on the

slug with your naked eye. Visually it was an

excellent evidence slug.

Q. As you looked at it, did you think

that it could be matched easily if it was in

fact the death slug?

A. It was a very small room I guess this

courtroom, certainly the criminal courthouse,

and when I saw that slug, I knew right then

if the James Earl Ray fired that slug, we

were going to see every expert that you can

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

662

imagine in the whole world to put that slug

with that rifle. It just didn't pan out that

way.

Q. Judge Haynes, as a result of your

intensive trial preparation and analysis of

the State's case right up to that November

date, how did you believe that a sitting jury

at that time analyzing that evidence and

weighing that charge would have voted?

A. Well, of course, all a trial lawyer

can do is the best he can in assessing what a

jury is going to do. I have considered in my

thirty-five-year career a jury is the best

lie detector there is. But we felt like the

jury would, if it would follow the law and

the evidence, that on the evidence available

and the law in the case, there was virtually

no chance that the State could prove beyond a

reasonable doubt that James Earl Ray could

have acted alone in firing the shot that

killed Dr. King.

MR. PEPPER: Nothing further.

Thank you.

CROSS-EXAMINATION

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

663

BY MR. GARRISON:

Q. Judge Haynes, I'm Lewis Garrisoin

representing the Defendant Loyd Jowers. I'm

going to ask you a few questions.

During your interviews with Mr. Ray

and the others you interviewed, did they ever

mention anything going on in James Grill

located here next to the rooming house?

A. Yes, sir. James Earl Ray said at

some point in the afternoon -- he said he had

an accomplice, an associate by the name of

Raul. He said at some point in the

afternoon that one or both of them had gone

into Jim's Grill I think to have a beer. We

interviewed everybody we could lay our hands

on who was in Jim's Grill and could find no

corroboration that they went in there.

Q. Did you ever hear the name Loyd

Jowers mentioned in the investigation?

A. Yes, sir.

Q. In what capacity was he mentioned?

A. Renfro Hayes was an investigator who

worked for us at the time. We had hired

Renfro because, among other things, he knew

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

664

that area of town and a lot of people

involved.

Q. I knew Mr. Hayes well.

A. Then you know what I'm talking

about. Hayes knew Loyd Jowers and at the

time Loyd Jowers was operating Jim's Grill.

Hayes reported back to us that there was

nobody in Jim's Grill that had testimony to

offer that would in any way affect the case.

We had so much ground to cover, we just

excluded that.

Q. Did you ever hear the name Frank

Liberto mentioned by Mr. Ray or anyone during

your investigation?

A. I never heard the name Jowers or

Liberto mentioned by Ray at all. The answer

to that question is no. I think I heard the

Liberto name -- yes, before today I've heard

the name Liberto. I know that Hayes

mentioned it to me maybe in the 1970's but

not contemporaneous with this.

Q. Did you make some effort to locate

this person called Raul?

A. Yes. To some extent. To some

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

665

extent. Bear in mind the question we had on

the table was defending a murder case, not

proving who killed Dr. King. Therefore, our

focus was different than the search for

Raul. But if you want me to go forward to

the extent that we were interested in him --

Q. Yes.

A. -- there was some information about

New Orleans. We thought it was very -- there

was something about it that triggered us as

being very important. In fact, Ray told us

the reason the rifle was in Memphis was that

it was part of an operation to bring guns

from Mississippi down to New Orleans to Cuban

revolutionaries.

We wanted to go to New Orleans. We

thought it was very, very strange that James

Earl Ray refused to allow us to go to New

Orleans. He instructed us that no matter

what happens, to do nothing to investigate

that connection.

To that extent, yeah, we were trying

to trace down -- if nothing else, to -- a

criminal case, as a criminal lawyer, you try

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

666

to make your case on the evidence. You just

cannot rely on what the client tells you. To

some extent we were trying to corroborate

what he had told us, but he wouldn't let us

go.

Q. Judge, did Mr. Ray ever tell you that

he -- let me ask you, first of all, did you

really think there was such a person name

Raul?

A. It was inescapable to us that there

weren't conspirators.

Q. I spent two days taking his testimony

in prison. He never could tell me at any

time that anyone ever saw him with this

person named Raul.

A. Mr. Garrison, we looked and looked

just for that, something that would

corroborate that, to no avail. In fact,

that's why we were interested in the Jim's

Grill people, because that was

contemporaneous. We were looking for

anything, anybody that saw a stranger there

who knew Ray or, ideally, Ray with a

stranger. But nobody there at that time

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

667

would say anything about that.

Q. Did you ever learn at any time that

there was a witness who saw someone in the

brush area? Did anyone ever tell you that,

that they actually saw some person that in

that brush area?

A. If I may reflect on the question you

are asking. The only person that we talked

to who we believe ever knew who fired the

shot was a man in the rooming house. I'll

tell you about him in a minute if you are

interested.

As far as the brushy area is

concerned, there were some associates of Dr.

King who were on the hotel side of the street

who said that they thought the shot came from

there. But that was all regarding that

issue.

MR. GARRISON: Thank you, Judge

Haynes. Nothing further.

REDIRECT EXAMINATION

BY MR. PEPPER:

Q. Judge Haynes, I know you said you did

an extensive investigation of potential

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

668

witnesses. Were there any Memphis Police or

Fire Department witnesses the State shared

with you?

A. I know we received none as far as the

police or fire department.

Q. But you uncovered some of these

witnesses yourself?

A. Sure, yes, sir.

Q. Are you familiar with the contention

of the prosecution at that time that the

bullet has fired from the bathroom window of

the rooming house?

A. Yes.

Q. And that it was fired from the

bathroom window, having been rested on a

window sill?

A. I think so.

Q. And that the prosecution claimed that

a dent in that window sill was made by the

rifle itself?

A. I've heard that. I just cannot

believe that they would have actually tried

to prove that in court, though. That's

beyond belief.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

669

Q. Well, would it surprise you to learn

that in fact at the guilty plea hearing on

March 10th, 1969, this contention was put

forth as a matter of certainty that it could

be proven that the dent was caused by the

rifle?

A. I would be shocked if a lawyer said

they could prove that with certainty based

upon what I know of the layout.

Q. Did they turn over to you at any

point in your investigation FBI reports with

respect to laboratory analysis of evidence?

A. No, sir. Of the window sill?

Q. Yes.

A. I don't think so.

Q. It has been entered into these

proceedings as evidence, plaintiffs'

evidence, those reports which indicated that

they could in fact not prove that the window

sill -- that the rifle rested on the window

sill.

A. A report saying that they could not

prove that?

Q. Yes.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

670

A. I didn't need a report. I could see

the window sill and the rifle. That just

wasn't an issue.

Q. I'm just wondering if that was

disclosed to you in the course of your

investigation, that report?

A. I don't remember, Mr. Pepper,

specifically. I know this: There were reams

and reams of evidence, much of which, as soon

as we realized what it was, we were on to

something else. We just didn't have time to

chew on every little piece.

The window sill -- you could not

prove that that rifle rested on that window

sill. There is no way. We know that as

lawyers. If we saw a report that said we

can't prove the rifle rested on the window

sill, we would just flip that over and say,

sure, and then move on.

MR. PEPPER: Judge Haynes, thank

you very much.

MR. GARRISON: No questions for

Judge Haynes.

THE COURT: You may stand down.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

671

THE WITNESS: May I be excused?

THE COURT: You may.

(Witness excused.)

MR. PEPPER: The plaintiffs call

Ms. Bobbie Balfour.

BOBBIE BALFOUR

Having been first duly sworn, was examined

and testified as follows:

DIRECT EXAMINATION

BY MR. PEPPER:

Q. Good afternoon, Ms. Balfour.

A. Good afternoon.

Q. Thank you very much for coming here

this afternoon.

A. Oh, you are welcome.

Q. Would you please state for the record

your full name and address.

A. Bobby King Balfour, 422 (Inaudible.)

Q. Ms. Balfour, are you presently

employed?

A. Yes, I am.

Q. What do you do?

A. I'm a cook.

Q. Where do you work?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

672

A. At Embassy Suites on American Way.

Q. In 1967 and 1968 were you employed at

Jim's Grill on South Main Street in Memphis,

Tennessee?

A. I probably was, sir, but it has been

so long, it is hard to remember what year it

was.

Q. Well, do you remember being employed

in Jim's Grill at the time of the

assassination of Martin Luther King?

A. Oh, yes, I do, uh-huh.

Q. On April 4th, 1968?

A. Right.

Q. And who was your employer at that

time?

A. Loyd Jowers.

Q. Mr. Jowers, Loyd Jowers?

A. Uh-huh.

Q. What were your duties then,

Ms. Balfour, at the time?

A. Waitress and cook, all around. I did

everything.

Q. So you waited on tables and you

cooked and you --

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

673

A. Short-order cooked and cooked.

Q. Goodness. How many hours a day did

you work?

A. We came to work in the morning time

when he'd pick us up about four-thirty and

stay there as long as he needed us.

Q. So you started at four-thirty?

A. Yeah. He would pick us up.

Q. He would pick you up and drive you?

A. Uh-huh.

Q. And who else did he pick up?

A. Another lady was named Rosetta.

Q. On April 4th, 1968, did he pick you

and Rosetta up on that day as well?

A. I don't don't think Rosetta came to

work that day, but I did.

Q. Do you think you were picked up by

Mr. Jowers and independently taken to work on

that day?

A. I know I was.

Q. You know you were?

A. Uh-huh.

Q. And you started at the usual time

that morning?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

674

A. Uh-huh.

Q. Now, in the course of your work at

Jim's Grill, were you familiar with a lady

who lived on the second floor just above the

grill in the rooming house named grace

Stephens?

A. Yes. I would take her breakfast.

Q. You used to take her breakfast?

A. Uh-huh.

Q. What time did you take her breakfast

up there as a rule?

A. Between eight-thirty and nine

o'clock, somewhere like that.

Q. Eight-thirty or nine o'clock you

would take her breakfast up?

A. Yeah.

Q. And would you leave the food with her

and then come back downstairs?

A. I would set it beside the bed.

Q. And then would you go and get the

dishes at another time?

A. No.

Q. What happened to the dishes that you

left there?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

675

A. I don't know, but I guess they got

back. I didn't bring them back.

Q. So you didn't bring them back?

A. No.

Q. So you just went up -- you delivered

the breakfast to her?

A. Right.

Q. Why was that? Was she ill?

A. She was in bed all the time.

Q. She was in bed all the time?

A. Uh-huh.

Q. Do you know if she had an illness or

sickness?

A. No, I don't, didn't know what it was.

Q. You didn't know?

A. No.

Q. How long did you have that practice

of going up there and delivering her

food?

A. Oh, just sometimes. I didn't go all

the time because sometimes Rosetta went.

Q. Sometimes Rosetta went?

A. Right.

Q. Was Rosetta working that morning on

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

676

April 4th, as you recall?

A. I don't think so. It has been a long

time. I can't hardly remember, though. I

don't think Rosetta worked that day.

Q. You don't think she did?

A. I don't think she did.

Q. You were there alone?

A. No, I wasn't there alone. He had

another girl there, too.

Q. He had another girl working there?

A. Yes.

Q. Ms. Balfour, did you take breakfast

up to Ms. Grace Stephens that morning?

A. No, I did not.

Q. And why didn't you take breakfast up

to Mrs. Grace Stephens that morning?

A. Mr. Jowers said I didn't have to take

it up there that day.

Q. Mr. Jowers said you didn't have to

take it up there that morning?

A. Uh-huh.

Q. So he told you not to go upstairs

with the breakfast that morning?

A. Right.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

677

Q. Did he explain to you why he did not

want you to go onto the second floor of the

rooming house?

A. No, he did not.

Q. Did you ask him?

A. No.

Q. You just followed him because he was

the boss?

A. Right.

Q. Do you know if Grace Stephens got her

breakfast that day?

A. I don't know.

Q. Ms. Balfour, how long did you work on

that day?

A. Well, I went in that morning, and I

don't know the exact time it was, but just as

I run across the street just in time to catch

the bus, then I made it in the house and it

came on the TV that King had got killed.

Q. So you left Jim's Grill sometime

early prior to the assassination, and by the

time you got home, you heard about it?

A. Right.

Q. Now, did you go to work the next

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

678

morning?

A. Yes, I did. He picked me up.

Q. Mr. Jowers picked you up the next

morning?

A. Right.

Q. And he drove you to work?

A. Right.

Q. In the course of that ride to work

the next morning, do you recall if he

mentioned a rifle to you?

A. No. I remember him saying, you

should have been here last night, we had a

lot of excitement. I asked him what was he

talking about. He said that the police had

come through our place of business and found

a gun.

Q. The police had come through the

restaurant?

A. Right.

Q. And found a gun?

A. Uh-huh.

Q. Where did they say they found the

gun?

A. In the backyard.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

679

Q. In the backyard?

A. In the backyard.

Q. Did you ever look out into that back

area through the back door?

A. I have looked out that back door, but

it was kind of woody out there, a lot of

grass, weeds and stuff out there.

Q. Could you describe that area as you

recall it as you looked onto it?

A. There was a lot of grass out there,

you know, little trees that had grown up back

there. It was in bad shape back there.

Q. Bad shape?

A. Uh-huh.

Q. Mr. Jowers said the police came

through there and they found the gun in that

back area somewhere?

A. Right.

Q. Did he say anything else about the

finding of the gun or about the events of the

night before?

A. Ug-huh.

Q. Nothing more than that?

A. No.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

680

MR. PEPPER: Nothing further.

CROSS-EXAMINATION

BY MR. GARRISON:

Q. Ms. Balfour, you had gone to work

that day at the grill about four or five

o'clock in the morning?

A. Right.

Q. Mr. Jowers as usual had come to your

home and gotten you that morning and took you

on to work?

A. That's true.

Q. Let me ask you something. On the day

that this occurred, April the 4th, 1968, that

was a Thursday, had you worked all that week

as you recall?

A. Yeah.

Q. Did you ever see any money in that

restaurant, anyone bring any money?

A. No.

Q. You were there most of the time in

and out of the back?

A. Yes.

Q. Did you ever see a gun?

A. No.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

681

Q. No gun at all?

A. No.

Q. Did you ever hear Mr. Jowers make any

statement before it occurred about the

assassination of Dr. King or Dr. King, any

talk about that at all?

A. No, Jowers wasn't that type person.

Q. He was not prejudiced at all, was he?

A. No, he wasn't.

Q. Very fair, wasn't he?

A. He sure was.

Q. Did you ever see any police officers

in the grill before the assassination of Dr.

King, did any of them come in on a regular

basis?

A. No.

Q. Let me ask you, Ms. Balfour, on the

day of the assassination, what time did you

leave?

A. I don't know what time it was, but it

was kind of late. Because after I made it in

the house, it came on the TV that King had

got killed.

Q. Did you see any new faces that were

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

682

there, any strangers in the grill that day

that you remember?

A. No.

Q. Now, as far as taking the breakfast

to Ms. Stephens, do you know if Mr. Stephens

was paying Mr. Jowers for this?

A. No, I sure don't. Charlie Stephens

paid him all the time.

Q. In fact, that day Mr. Jowers had run

Mr. Stephens out of the restaurant because he

was so drunk he told him to get out of there,

didn't he?

A. Several times.

Q. That had some problems, didn't they?

A. Yeah.

MR. GARRISON: That's all.

THE COURT: Anything further of

this witness?

MR. PEPPER: Just briefly, Your

Honor.

REDIRECT EXAMINATION

BY MR. PEPPER:

Q. Mrs. Balfour, were you -- did you

ever give a statement to the police or any

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

683

investigating authority about what you told

this Court today?

A. After King got killed?

Q. Yes.

A. No, they never did ask me.

Q. I'm sorry?

A. No, didn't nobody ever question me at

that time. When they came in that next day,

they asked me a question, but when I gave

them an answer, they told me to go back in

the kitchen.

Q. They told you what?

A. Go back in the kitchen.

Q. Told you to go back in the kitchen?

A. Uh-huh.

Q. They asked you a question, you gave

them an answer, and they told you to go back

in the kitchen?

A. Right.

Q. And no investigating authorities had

ever questioned you about what you saw or

what you heard or anything?

A. No.

MR. PEPPER: Thank you very

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

684

much, Mrs. Balfour.

MR. GARRISON: Let me ask you

one other thing.

RECROSS-EXAMINATION

BY MR. GARRISON:

Q. Did anyone from the police, FBI or

Sheriff's Office ever come into the grill

while you were there to look around,

investigate anything after the assassination?

A. No.

MR. GARRISON: That's all.

THE COURT: You may stand down.

(Witness excused.)

MR. PEPPER: Your Honor,

plaintiffs call the clerk of the criminal

court, William key.

WILLIAM R. KEY

Having been first duly sworn, was examined

and testified as follows:

DIRECT EXAMINATION

BY MR. PEPPER:

Q. Good afternoon, Mr. Key. Thank you

very much for coming here this afternoon.

Would you state your full name and address

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

685

for the record, please.

A. William R. Key. I live at 1574

Cherry Park Drive, Memphis, Tennessee, 38120.

Q. Mr. Key, would you tell the Court

what is your present position?

A. I'm the criminal court clerk of

Shelby County.

Q. What are your responsibilities as the

clerk of the criminal court?

A. Basically the clerk of the court is

the keeper of the records. In our case, we

also keep the property and evidence.

Q. And you maintain an evidence room

over in the criminal court clerk's office?

A. That is correct, on the 4th floor.

Q. When you keep property in that

evidence room, what is the nature of the

property that you keep there?

A. Those properties are brought in for

court proceedings, and after that we continue

to hold the property until the case disposed

of, some of it for twenty, twenty-five years.

Q. And has the property in the case

relating to the assassination of Martin

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

686

Luther King been kept in your office or

property room?

A. The property in the case of Martin

Luther King's death is kept in a vault. We

have a large room larger than this room here

where most of the property is kept. However,

in the case of the King killing, it is kept

in a safe that is separate from that where we

keep money and diamonds and things of that

nature.

Q. Would you say that all of the

evidence in that case that is known that has

been turned over is kept in that facility?

A. That is correct. There are thirteen

boxes of it, two hundred sixty-seven items.

Q. It is under your direct supervision?

A. That is true.

Q. Your care and custody?

A. Yes, sir.

Q. That evidence that has been kept in

that vault in terms of its custodial chain,

it has been kept in that vault since 1968?

A. Not in this particular vault. The

criminal court clerk's office was moved

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

687

across to 201 Poplar from 157 Poplar, and

when it was moved there, it was formerly in a

vault in 157, and when we moved into the new

quarters there at 201 Poplar, it was moved

there in 1981.

Q. So it has moved to a different

facility?

A. Yes.

Q. But it has always been under the

supervision, control, care and custody of the

clerk of the criminal court, which includes

your predecessors?

A. Yes, sir.

Q. You are the most recent in a long

line?

A. Five years. I've had it for five

years. Previous to that Mr. Blackwell had

it.

Q. Now, Mr. Key, are you in attendance

here this afternoon under subpoena?

A. Yes, I am.

Q. Have you been asked to bring a piece

of evidence with you to this courtroom?

A. That is correct.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

688

Q. And what is that evidence that you

have brought here to show us?

A. The rifle that is purported to have

been the weapon that slew Dr. King.

Q. This is the evidence rifle in the

case, the assassination of Dr. Martin Luther

King?

A. That is correct.

Q. Is that evidence in this courtroom?

A. Yes, it is.

Q. Where is it?

A. It is over there.

MR. PEPPER: Your Honor, if the

evidence may be brought forward.

THE COURT: Go ahead. Test it

to make sure it won't fire.

(Rifle passed to the witness.)

Q. (BY MR. PEPPER) Now, do you recognize

that as the evidence rifle in the case, the

alleged murder weapon of Dr. Martin Luther

King?

A. Yes, it is. This is the weapon that

we've had since I've been there, and it was

taken to Rhode Island and Pennsylvania for

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

689

firing and testing.

Q. That is the weapon that has been in

the care and custody and has not been

tampered with or exchanged or replaced in any

way?

A. That is correct, since I've been

there. Before I came into that office, I

can't testify to that, but I have some

feeling that it was kept there in the office

that we presently keep it in.

Q. Mr. Key, is that rifle presently, as

far as you are aware, capable of being used?

A. Yes, it is. It still is. We

witnessed it being fired in Pennsylvania and

Rhode Island.

MR. PEPPER: I have nothing

further of this witness.

MR. GARRISON: I have no

questions for Mr. Key. I know Mr. Key well.

I've known you many years. What is it,

forty?

THE WITNESS: A few years.

THE COURT: Let me see it.

(Rifle passed to the Court.)

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

690

MR. PEPPER: It is a 30-06 760

Gamemaster. Your Honor, we would just like

the jury to have a visit with that weapon, if

it is possible.

THE WITNESS: Let me mention

this. I am under court order that no one

examines it nor holds it.

THE COURT: You may hold it for

their inspection.

MR. PEPPER: Nothing further, Your

Honor. Plaintiffs would like the weapon to

remain in the courtroom for the next

witness.

THE COURT: Is the next

testimony concerning this?

MR. PEPPER: The next witness is

on his way, yes.

THE COURT: Would you stay?

THE WITNESS: We will stay

here.

THE COURT: All right.

(Witness excused.)

JOE B. BROWN

Having been first duly sworn, was examined

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

691

and testified as follows:

DIRECT EXAMINATION

BY MR. PEPPER:

Q. Good afternoon, Judge.

A. Good afternoon, sir. How are you.

Q. If you would state for the record,

please, your full name address.

A. Joseph B. Brown, business address,

201 Poplar.

Q. Thank you. What is is your present

position, sir?

A. I'm a state judge for the 30th

Judicial District, State of Tennessee,

Division IX, Criminal Court of Shelby County.

Q. Are you testifying here this

afternoon voluntarily or under subpoena?

A. Under subpoena.

Q. Thank you again for joining us.

Judge Brown, would you tell the Court some of

your qualifications and professional

training.

A. All right. I have a law degree from

the University of California, Los Angeles,

1973. Came out here -- let's see. I've been

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

692

a member of the bar of the State of Tennessee

since 1975, worked for Legal Services here,

then the Equal Employment Opportunity

Commission.

I was I believe the first black

prosecutor for the City of Memphis and I ran

the City Public Defender's Office for awhile,

then I went into private practice, and in

1990 I was elected judge for Division IX of

the Criminal Courts, August of 1998

re-elected for another term.

Q. Prior to your law career, could you

tell us what was your professional training

and what was your --

A. You mean relative to the subject at

hand?

Q. Relative to the subject at hand.

A. I've always had an intense interest

in the field of ballistics, firearms and such

like. I've been a hunter, target-shooter.

It is sort of a hobby of mine.

At one time in life I thought when I

night go into criminal law it was a decision

I made to get as much into the subject as I

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

693

might so I would be able to properly defend

certain defendants.

Q. Over what period of time did you

develop this knowledge and experience with

weapons?

A. Let's see. My father taught me to

shoot when I was six years old. So that

would be going on too close to fifty years

ago.

Q. And had you on your own studied and

read about the science of ballistics and

weapons?

A. I have.

Q. Over what period of time have you

done that?

A. About the last forty years or so.

Q. How long have you handled weapons of

various kinds?

A. Like I said, starting about six or

seven years old.

Q. How long have you handled or had

experience with rifles such as the type

involved in this case?

A. I'd say thirty, thirty-five years

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

694

worth of experience.

Q. And during the course of that

experience, have you explored the nuances of

ballistics and the matching of bullets to

particular weapons?

A. I have, sir.

Q. Are you familiar with the techniques

used in that process?

A. Yes, sir, I am.

Q. Have you familiarized yourself with

the types of weapons and the types of bullets

that go with those weapons, the range of

weapons?

A. I have, sir.

MR. PEPPER: Your Honor,

plaintiff would move that Judge Brown be --

Judge Brown's testimony testimony here be

admitted as that of an expert for the purpose

of this discussion.

MR. GARRISON: I certainly agree

and have no objection.

THE COURT: All right. You may

proceed.

Q. (BY MR. PEPPER) Judge Brown, would

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

695

you please initially begin a discussion so

that the Court and the jury can become aware

generally of what the science of ballistics

is about and how it is practiced.

A. Actually what ballistics is about is

the flight of projectiles, in other words, a

projectile that has an initial impetus placed

upon it such as a ballistic missle, where

there is a thrust at the beginning of the

flight of the object, a projectile fired out

of a catapult in Ancient Roman times where

there is a slinging of an object, what

happens once it gets that initial impetus,

closely at hand what happens when you fire a

bullet, projectile, from a rifle or pistol or

such like, how does it behave as it travels

from its point of firing to its target or

until it impacts the ground or, in other

words, stops its forward flight.

Now, in that process there are

certain specified or special categories such

as studying the internal ballistics they call

the subject, that is how does a projectile

behave in the barrel of a weapon, what

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

696

happens when you take one of the

self-contained cartridges that are about

universal today, put that in the appropriate

weapon, pull the trigger and fire it, what

happens. Those are called internal

ballistics. That is called internal

ballistics.

One of the things that is common

today is to take a projectile, a bullet, if

you would, that has been found in the body of

the victim of a homicide or a wounding and

attempt to compare that bullet with the known

sample fired from the suspect weapon. What

commonly happens is the bullet is placed in a

device that amounts to a microscope where the

examiner can carefully move the suspect

bullet around and then take the known sample

and attempt to compare it using striations,

which are fine grooves that are engraved on

the bullet based on the particular

characteristics of the weapon.

There are basal or base

characteristics that are determined by the

nature of the weapon, what caliber it is, who

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

697

the manufacturer is, and then there are

individual characteristics of weapons that

are brought about by manufacturing flaws.

Nothing is perfect, and everything

that is manufactured basically is going to

leave some tool marks in the bore of the

weapon. The idea is to see if you can

compare the individual signature of a weapon

that it would leave on a specimen or bullet,

sample bullet, and see if you can match that

up with the bullet that you have removed from

the body of the victim.

Q. Right. Your Honor, would you

describe for the jury the kind of bullet,

projectile -- but bullets are we're talking

about here -- that is involved in this case?

A. We're talking about a bullet that is

nominally a .308 diameter, commonly known as

a .30-caliber bullet. The allegation of the

State was that that bullet was fired from a

weapon known as a 30-06, in other words,

a .30-caliber weapon firing a cartridge

that was based on a military cartridge known

as .30-caliber of 1906.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

698

It was a modification of the

earlier .30-caliber of the model 1903 which

resulted in a shortening of the case neck of

that cartridge, a reduction of the weight of

the initial military bullet from 220 grains

down to appointed 150-grain bullet. That

became known as a 30-06.

The actual caliber of the projectile

is .308. In European terms that is known as

a 7.62 by 63 millimeter cartridge. We know

it as a 30-06.

Q. Judge, would you describe for the

jury the difference between a military bullet

or a hard point and a solt-point bullet?

A. As a result of the Geneva Convention,

the military establishments of most of the

world agreed to not use expanding bullets for

humane purposes. In the latter part of the

19th Century, the English in India were

concerned about the lack of stopping power

that their bullets showed on some of the

native population, so they had a dumb dumb

arsenal in India.

They started producing a bullet with

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

699

a large amount of lead exposed at the tip of

the bullet, and in certain instances hollow

pointed, that is, the bullet has a hole in

the front or a large amount of lead exposed,

and that would cause the bullet to expand

when it hit flesh, which would result in a

recovered bullet looking something like a

mushroom. That caused a very, very bad

wound.

So as a humane matter, most of the

world has agreed not to use soft-point

bullets, and they use what they call full

metal jacketed bullets, where the point of

the bullet is covered with a gilding of steel

or brass or composite jacket so it does not

expand. Most bullets still have a lead core.

Q. Would you explain how the bullets are

manufactured by various manufacturers in

terms of the composition of the lead and the

similarity from batch to batch?

A. Regarding the case at hand, the

situation is this: A manufacturer, say

Remmington, Winchester or Olin, Federal, when

they make up a batch of bullets, they are

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

700

faced with this: They do not have any

machines that are dedicated to one particular

type of bullet. So what happens, they may

make a run of twenty-five million or

thirty-five million of a given type a bullet,

say 150-grain .308 bullets.

Then after they make that run, they

may switch over to 6.5 millimeter with the

same machine and run fifteen to twenty

million of those. Then when it comes time to

convert it back to .30-caliber, which was

the .308, they can't get the tolerances

exactly as they were before, so what they

tend to do is they run batches which they

call lots, L O T S, and they give each batch

a lot number.

When they load up ammunition, that

is, the completed cartridge, they generally

try to make the lots consistent so that the

customer can be assured that he will get

reasonable accuracy and predictability with

any cartridge that he buys from this

company.

So what happens is they have a lot

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

701

of bullets or a batch of bullets with an

assigned lot number. The powder varies, too,

from one batch number, so they'll have a lot

number assigned to a particular batch of

powder and they'll have a batch with a lot

number assigned to the cartridge case that is

to be used in the loaded cartridge. They

will also do the same with primer.

So when they make a run, a batch of

these cartridges, everything will have

similar lot numbers, in other words, the

bullets might be EO71565J3 with a number on

that, and the same with the cartridge. They

will use the same run or batch of lead, the

same run or batch of gilding, the same run or

batch of copper or alloy or brass for the

cartridge case and the same applies.

So what happens is if you run a

metallurgical analysis on any of the

materials, you will expect to find that there

is a metallurgical consistency from one

cartridge to the next in the same batch, from

one sample of powder taken out of a cartridge

with another in the same batch, and the same

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

702

with the bullets, the gilding metal of the

jacket will be the same and the lead cores

would be the same.

Q. Thank you, Judge. Have you

familiarized yourself with the death slug in

this case?

A. I have, sir.

Q. Have you familiarizeed yourself with

other bullets and cartridges that were found

in an evidence bundle in this case?

A. Yes, sir. What seems to have

happened is that when the rifle in question

was recovered, there were four unfired

cartridge cases that were recovered along

with the rifle and one fired cartridge case.

A primitive metallurgical analysis done some

thirty years ago revealed or suggests that

the fired cartridge case and the four unfired

cartridge cases are metallurgically

identical, that is, they are from the same

lot.

The bullets from the four unfired

cartridge cases are metallurgically identical

when the lead cores are analyzed, whereas the

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

703

bullet removed from Dr. King is not

identical. It is metallurgically different

in its composition, which would suggest it is

not from the same lot. That would be totally

contrary to the policies of the ammunition

companies.

Q. Let us understand what it is you are

saying here. It is that the evidence bullets

that were found in the bundle, the evidence

bundle that was dropped, have a different

metallurgical composition than the slug that

was taken from Dr. King's body?

A. That's correct.

Q. Are you saying --

A. Further, the significance of that is

developed by the fact that this cartridge

case that appears to have definitely been

fired in the rifle that is in evidence is in

fact of the same lot as the other four

unfired cartridges. You would expect the

bullet that had been removed from Dr. King's

body to have been of the same lot.

That suggests that this bullet was

not fired from that empty cartridge case that

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

704

was found with the rifle, and it was

definitely fired in the rifle as per some

tests that were run on that cartridge and

that rifle and other sample cartridges.

Q. All right. Thank you. Now, would

you tell the jury about the nature of the

weapon -- we're going to take a look at that

in a minute -- but the nature of the weapon

as you understand it, the alleged murder

weapon in this case?

A. The murder weapon in this case is a

Remmington 760 Gamemaster, caliber 30-06.

Q. And what is significant about the 760

Gamemaster rifle in terms of its comparison

with other 30-06's?

A. It is what is known as a pump-action

rifle. It is basically the only one still

manufactured in America, though Browning last

year came out with a weapon similarly

activated.

At one time it was popular, but over

the years since the end of the 19th century

that is basically the only remaining

center-fire pump-action rifle. There is also

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

705

a slightly different version of that which is

a semiautomatic weapon.

Q. Is there a counterpart weapon that is

a military issue?

A. Well, I wouldn't say it is exactly a

counterpart, but what you are talking about

is .30-caliber weapons generally. It is

perhaps the most popular caliber in America.

You have several weapons that will

fire an identical bullet. By that, I mean

that if you manufactured a lot of or a batch

of these bullets, you could load those

bullets correctly in several different

caliber weapons.

One is what is known as a 308

Winchester, which is a civilian nomenclature

applied to something known as a 76 2x51 nail

round. It was adopted in 1954 by the U. S.

Government and most of the NATO forces after

some tests. It also fires a .308 bullet.

Likewise, there is what is known as

a 300 Holland & Holland Magnum, a 30 Supra is

another name for it, and it fires a .308

bullet, the same one. It you hand load, you

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

706

can take a .308 bullet that you would buy in

a gun shop, and if it is suitable for your

purposes, you could load that in a 308

Winchester, a 30-06, a 300 H&H, also in a 300

Winchester Magnum.

You can load that very same bullet

in a 300 Weatherby. Now you can load it

in -- let's see, I'm talking about factory

ammunition only -- a 30 x 378 Weatherby, and

they have a 330 Super Magnum that Remmington

has that will take the same bullet.

There is something Laseroni has out

called a WarBird, a very specialized thing.

There is a company called Dakota that puts

one out. They all use this exact same .308

bullet.

Now, what happens, back to your

question about the military, is currently,

since it is a standard NATO round, you have

such items as the M-60 machine gun, which

we're not talking about here, but you do have

what is known as the M-14, which was adopted

in 1956 as the standard battle weapon for the

U.S. military, that is, the Marine Corps and

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

707

the Army, that has been superseded by the

M-16 family of weapons.

There is also an M-21, which is a

sniper edition of the M-14. You have an

M-24, which is a Winchester Model 70 that the

military used in the late 1960's that was a

bolt-action sniper weapon.

You have a version of the Remmington

700 bolt-action weapon that the military

currently uses as a sniper weapon, along with

refurbished editions of the M-21. You have

various and sundry permutations of weaponry

that are .30-caliber that the military has

used from time to time.

On the civilian market there are

also a number of semiautomatic weapons that

had military intentions initially, such as

the F. N. Fowl that was commonly available

and the G3/H and K91, which are available

from time to time. So there are a number of

weapons that will be such as to fire a

similar bullet.

Q. And were there a number of weapons

that could fire such a bullet back in 1969?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

708

A. There were. A number I could think

of. The 308 Winchester was popular.

The 30-06 was even more popular at the

time. Those two would have probably been

what you would have encountered if you were

talking about a hunting caliber center-firing

30-06 or a 308 Winchester. You also have

the old .30-30, which fires a similar

diameter bullet, but that would be a

blunt-nosed slug, which is an entirely

different design for feeding through a

tubular magazine.

You also had a.30-40 Frig that was

this use starting from 1892 and the U.S.

military used a .308 slug,, and if somebody

was shooting one of those, you would have had

it firing a similar bullet. Or if someone

hand-loaded it, that would still be the

case. There were very many foreign copies of

the same weapon.

Q. So any one of those range of weapons

could have fired this type of slug at that

time?

A. That's correct, sir.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

709

MR. PEPPER: If it please the

Court, I'd like to have the witness examine

the weapon in evidence.

(Rifle passed to the witness.)

Q. (BY MR. PEPPER) Do you recognize that

weapon?

A. Yes, that's the 760 Gamemaster in

evidence in this case.

Q. What can you tell the jury about this

particular weapon?

A. Although it doesn't exactly look it

right now, it is a fairly new weapon. It has

a Redfield 2 to 7 variable scope on it. It

is mounted in Weaver scope rings, and mounts

it is a pump-action weapon. And it is

from the evidence, the marking on the

barrel, 30-06 in caliber.

Q. Did you have occasion to consider

this weapon as the murder weapon in this case

in some degree of depth and careful

consideration?

A. I did, sir.

Q. When was that?

A. That was during the course of

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

710

proceedings brought by the late James Earl

Ray, what are known as post-conviction relief

proceedings to challenge his conviction.

Mr. Ray had never confessed to the

killing of Dr. King, but he had entered what

is known as an Alford versus North Carolina

plea. That is a plea delivered under the

principle of the case of Alford versus North

Carolina, which is a moderately old U.S.

Supreme Court case that stands for the

proposition that you may plead guilty even if

you are not actually guilty if you believe it

is in your best interest to do so, from all

of the proof in evidence you think it in your

best interest to do that and you did it

freely, voluntarily, knowingly, advisedly and

intelligently if the State otherwise has a

reasonable factual basis upon which to

proceed.

In other words, you might say you

may plead guilty even if you are not guilty

if you think that is in your best interest if

the State otherwise has a reasonable factual

basis upon which to proceed. In other words,

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

711

you might say you may cop out and plead

guilty even if you are not guilty if that is

in your best interest if the State has some

case that they can go forward upon.

The entirety of that case, according

to the petitioner's theory, was based on this

rifle, which is what hooked him up with the

case. During the course of reviewing the

record for this matter, it developed that

there was a transcript of James Earl Ray's

guilty plea.

It develops that Mr. Ray aforesaid

had never actually confessed to the killing

of Dr. King. I believe there are at least

two places in that transcript that revealed

that when an investigator for the District

Attorney's office testified during the course

of the guilty plea procedings and indicated

that James Earl Ray acted alone, in at least

one instance Mr. Ray rose and in sort of a

mild outburst indicated that that was not

true, that he did not act by himself,

whereupon a recess was taken. That happened

again. Another recess was taken. And then

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

712

he did not rise the third time. They then

went through the process.

It is not unusual, and we have a lot

of cases that are disposed of on what we call

Alford pleas. In other words, the defendant

has a criminal record that would be revealed

to a jury in the event that he testified

which might be something that he would be

leery of. There would be an instruction

given to the jury to the effect that if the

defendant testifies and you find that he has

any felony convictions, you are not to

consider this as touching upon his guilt or

innocence but you may consider it in terms of

evaluating his credibility.

Well, unless there is an exceptional

situation, and you get in front of a jury and

they find out you've got a criminal history,

they are not going to look at you as well as

they might have otherwise even in spite of

the instructions give by the judge. You may

think that the case is so outrageous or so

gross or horrible that you don't really want

to take your chances in front of a jury and

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

713

you will settle for what has been offered.

So that is what we had going on here

as far as the petitioner's theory. In other

words, at the time, considering the person

who was slain, the public outcry and uproar

and the possible sentence he could have

gotten, he thought it was in his interest to

enter what is known as an Alford plea.

Q. Now, Judge Brown, how long did you

preside over those proceedings?

A. I'd like to say about three years.

It all sort of shifts into a blur. It got in

my courtroom, there was at that time a set of

laws and cases that had been decided that

basically caused me to deny the petition of

James Earl Ray for not being timely.

However, I did note that there was a

loophole in the existing laws in the State of

Tennessee, and it was this: A person could

be sitting on death row, let's say, and

through the use of DNA evidence he could

prove his absolute innocence. But unless he

had filed that case within the existing

statute of limitations for post-conviction

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

714

relief proceedings, which at that time was

three years, and raised that evidence or he

was able to avail himself of what was known

as petition of era crim nobis, which has been

an ancient thing, of within one year, then he

had no remedy.

The law abhors a situation which is

legal where there is no judicial remedy,

which, of course, the only thing he could do

was apply to the governor's office for

clemency.

So what I ordered is that the

petition would be denied, but I would allow

the petitioner to put on what is known as a

proffer of proof. In other words, if he were

allowed to present this evidence, this is

what it would show so an appellate court

could determine whether or not the law needed

to be reviewed.

Well, in any event, I ordered that

the rifle be retested. That was in

accordance with an order given by the late

Preston Battle, who was the original judge.

In 1968 Judge Battle entered an order that

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

715

said the rifle was to be tellsed since he was

not satisfied with the ballistics tests that

had been run at that point. But that rifle

was never retested.

So I ordered it retested. It went

to the Court of Criminal Appeals who went

along with the prosecutorial side of things

and declined to allow that rifle to be

retested and issued a stay.

Well, a few weeks after that stay

was issued, it developed that the

legislature, which I was aware of, had been

working on a new post-conviction relief

statute and they passed that statute and they

said if there is new scientific methodology

that would establish the innocence of a

petitioner, there is no statute of

limitations, and such post-conviction relief

petitions have no time limit on when they can

be filed and no time limit on when they can

be reopened for showing by new scientific

evidence or methodology that the defendant is

innocent. That is so you don't get someone

stuck on death row when there is methodology

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

716

such as DNA testing that would show he is not

the fellow.

Q. Judge Brown, in the course of

preceding over those proceedings for

post-conviction relief, did you consider very

carefully the testing history of that rifle

and familiarize yourself with it?

A. I did, sir. I thought that it was

totally inadequate. At the time this weapon

was tested by the FBI, what they did is they

took four cartridges and fired them through

this weapon into what is known as cotton

waste. If you fire a high-velocity

projectile into cotton waste, you totally

obliterate, that is, destroy, the fine

striations that would enable you to do a

valid ballistics test.

The only thing you can get to out of

that would be the basal characteristics, in

other words, the base characteristics, which

would be this weapon fired a .30-caliber

bullet of .308 in diameter, and it had four

lands and grooves with an apparent right-hand

twist.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

717

One thing they never did resolve out

of that was what was the rate of twist.

Historically 30-06's had rates of twist of

one full turn in every ten inches. Weapons

that are designed from the front end as 308

weapons have one full turn every twelve

inches, though there are examples of each

where the rifling twist is as the other would

be. It depends upon what you are trying to

achieve with the weapon, whether you think

you will fire a heavier bullet or a lighter

bullet for the caliber.

But, in any event, the tests that

they did indicated -- the tests that they did

were totally incapable of giving a valid

basis of comparison to determine whether the

bullet removed from the body of Dr. King was

in fact fired from this weapon.

Now, in any event, there are some

other things that happened that I became

aware of during the course of my examination

of the record. One thing, I believe Mr. Key

came up with this, that is when I asked for

an inventory of all evidence in the case, he

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

718

noted that there was a picture of the bullet

or the slug that was removed from Dr. King's

body before it was transmitted to the FBI.

That picture revealed that the bullet was

intact, though mushroomed.

What the FBI sent back after the

conclusion of the test was three jacket

fragments and three lead core fragments that

had been cut as though you were taking a

banana and just pulled the peels all the way

off of the banana and then took a knife and

cut the banana length-wise in three equal

sections.

Q. Judge, let me just stop you there.

Let me put this picture up. Is that the

photograph you referred to?

A. You found the picture, I see. It

looks similar to that. I can't say if that

is the actual item in evidence.

Q. Does it look similar to the evidence

photo? That was a photograph of three

fragments?

A. Right.

Q. So would you describe, as best can

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

719

you --

A. What you can see in the lower

right-hand corner is the jacket itself. It

has been peeled back by a mushroom process.

What you are looking at is the other two

items are pieces of the lead core.

Q. Would you explain how that could

occur.

A. Well, it could be that it was not a

very well-constructed bullet and it simply

fell out at some time during the course of

testing. But what I found later in there was

not just what you look at there but before

the jacket had been peeled back so there are

three separate fragments to the jacket

itself.

Q. So the bullet that was taken from Dr.

King's body was in one piece?

A. It was in one piece. It is a hunting

bullet. It is a soft-core bullet. That

bullet is designed for the human harvesting

of animals. You don't want an animal to

suffer. So what you want is for the maximum

energy of the rifle to be dumped into the

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

720

target so it dies quickly due to massive

injuries. It mushrooms so the bullet

transfers most of its energy into the animal

rather than putting a clean hole through it.

If you were to shoot an animal

between one hundred and about three hundred

fifty pounds, any of the animals that are

typical of this continent, with a 30-06 from

say under a hundred fifty yards, which would

be typical hunting range, if you got a solid

torso hit in the lung or heart area, you

could pretty much count on that animal

dying. That would be a non-survivable

wound.

You would dump the entire energy of

the weapon into the target, and that would be

about a ton and a half of energy at somewhere

between a hundred fifty yards down to close

to the muzzle.

In other words, if you fired this

weapon, you would have 150-grain bullet

moving at a nominal velocity, and with the

type of ammo they were likely to have had in

1968, at about twenty-seven hundred,

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

721

twenty-seven hundred fifty feet per second,

which would leave you going on three thousand

foot pounds of energy.

In other words, if you put a scale

in front of the muzzle of this rifle, one

foot in front of it, and fired it, you could

register what that bullet weighed, and it

would weigh about a ten and a half when it

hit this scale.

What usually happens is when you

shoot somebody with a military bullet, which

is a full metal jacket, you put a nice clean

hole in them and most of the energy is dumped

in the dirt or in a tree or rock behind the

target. If you shoot an animal with this,

you dump all the energy in the animal and it

expires quickly.

Generally hunters prefer these days

to have the bullet completely penetrate the

animal so you can leave a blood trail. But I

will assure you it leaves a much bigger hole

on the way out then it does going in.

If you shoot a deer, very seldom

will one of them drop right in its tracks.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

722

It will usually take off and run twenty-five,

a hundred fifty yards, and you've got the

task of tracking that animal through the

underbrush until you find the body which has

expired from blood loss.

If you shoot the animal right and

the bullet does not penetrate downward but

stays inside and disintegrates, which is

known as a bullet failure, then you may still

disrupt the animal's central nervous system

and it will drop in its tracks. That happens

from time to time.

Q. Judge, do you recall from the

evidence before you at that time how the

petitioner came to buy that particular rifle?

A. What seems to have happened from the

record is that James Earl Ray went into a

business that sold firearms and bought what

is known as a 243 Winchester. It is one of

the 308 rounds that we had been talking about

or at least the cartridge case, neck down,

to .243 caliber. In other words, about six

millimeters versus seven point six two

millimeter.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

723

He brought it back the next day and

advised the proprietor that he had been told

or advised to get a .30-caliber weapon,

whereupon he reportedly purchased this item

right here and they mounted a scope on this

weapon.

Q. Judge, I'm going to come to the

scope, but could I ask you, was the 243

Winchester not an adequate rifle for the

purpose that this one was allegedly used for?

A. Actually a 243 actually probably

would have been a better weapon for the

purpose than this would have been, commonly

used to dispatch deer and also varments.

Also, it is a pretty accurate round, and

we're talking about a range that is less than

a hundred fifty yards, if you have any idea

of the ultimate layout of the scene, which is

Dr. King at the Lorraine Hotel with the

apparent point of firing being somewhere

within a hundred fifty yards.

Q. The 243 Winchester in fact was as

good or a better a rifle for the purpose of

assassination than that weapon?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

724

A. At least as well. It would have been

quite a bit better caliber than the one that

was used to kill President John F. Kennedy.

Q. Why, then, in your opinion, after

considering the varieties of the two rifles

and the choice ultimately settling on this

30-06, why was petitioner instructed to buy

this caliber rifle?

A. Based on the entirety of the record

and the entirety of the circumstances of the

case, it was my belief that it was so there

could be a number of common-caliber weapons

that might have been on the scene of the

killing.

Q. That would have had the same

caliber -- produced the same caliber bullet?

A. Same caliber bullet. If the test for

ballistic comparison purposes were run as

they were by the FBI, that is, firing the

sample projectiles into cotton waste so that

you could not get more striations on them so

you could compare the bullets with what was

taken from Dr. King's body, you would have

about sixteen or so million weapons that

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

725

could have been the one that fired this

bullet.

I think Remmington ultimately made

right now somewhere around eight or nine

million of these using the same barrel

machinery, either with this permutation of

the 760 Gamemaster, the 740 semiauto or the

Model 700 bolt-action series.

Q. Moving on to the scope, you were

about to tell us about what you concluded

with respect to the scope.

A. It is interesting in that the

proprietor of the shop never did what they

call polarimated this scope. You can't just

take a new rifle with a scope mount on it,

put some rings on it and then put a scope on

it and expect to hit anything. You've got to

zero the thing. That is not very neat.

There is a device called a

polarimeter, which looks like a small

telescope, that has a little spindle that

will fit down in the muzzle of this weapon.

Usually when you get a polarimater, they give

you a number of spindles that will fit most

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

726

common calibers.

You put that spindle-mounted

polarimater into the muzzle, you line it up.

There are some crosshairs on it. You take

these scaps right here of the scope and

you'll see in here a slot. What you do is

you move these screws or these devices around

using a coin until you get the crosshairs on

the scope matching the crosshairs on the

polarimater.

There is another alternative method

that you can use with a bolt action, which is

to take the bolt out, and the receiver will

be open. You lay this rifle on a sandbag and

you aim down the barrel itself at some item

about a hundred yards away, a small circular

item, and you try to align it in the middle

of the bore with the same amount of the bore

showing around this item. Then you

manipulate the adjustment knobs on the scope

to align the crosshairs with the item one

hundred yards away, and you keep looking back

and forth.

As you can see with this rifle, it

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

727

has got a closed receiver, so you cannot

bore-sight this using that particular

method. You'd have to polarimate it.

It has been my experience over the

last thirty years firing I don't know how

many hundreds of rifles that even when do you

get it polarimated or you bore a sight, right

after, when you take it out to the range to

finalize your sight-in process and you put up

a target at about twenty-five yards distance,

that I would say would be about the size of

one of these picture frames on the wall, you

might be lucky to get it in at the bottom

left-hand corner at twenty-five yards. Then

you'd have to dial in sixty clicks up, sixty

clicks to the right or left to get it close

on and then back out to a hundred yards and

then try to sight the thing in further, and

by a slow process make it so that the bullet

impacts where your crosshairs are located.

Now, usually what you do on a

.30-caliber weapon, if you are a hunter or

somebody else, you try and get the typical

bullet impact approximately two inches, maybe

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

728

an inch and be a half or two inches, above

point of aim. That would put your rifle dead

on at two hundred yards, maybe two fifty

actually, two hundred fifty yards.

That would mean if you fired at a

target with the weapon cited in like that at

twenty-five yards, you'd hit with a scope

like this on it about three quarters of an

inch to an inch below the target. At about

fifty yards you would start crossing over

that target line. At about sixty-five to

seventy you would hit right on.

At one hundred yards you'd be about

an inch and a half, inch point nine, maybe

two inches high. You'd be slightly over that

at two hundred yards. And at two hundred

fifty you'd be dead on. And at three hundred

you might be six or seven inches low.

So you would have to sight this

thing in. It does not appear that this

weapon was ever sighted in.

Now, there was also an FBI report in

the record that talked about this weapon

having been test-fired shortly after it was

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

729

taken into evidence. And that report

revealed that it shot several feet to one

side at a hundred yards and slightly half

that low. So this does not appear to have

been a sighted-in weapon.

Now, it is possible that it could

have been knocked out of zero, but this rifle

is not one for that to be something that was

as likely as it would be with other weapons.

You will note that it has got a

two-piece stock. This stock really is not

firmly affixed to the barrel. There is a

rod, an operating rod, upon which this slide

is affixed. That keeps it from having any

impact on the barrel at all. This barrel is

fixed tight with the receiver. You simply

have a butt stock here which keeps this thing

from occurring like your typical bolt action

where there is wood that goes all the way up

the receiver and up along the barrel which

tends to warp one way or the other depending

upon the temperature and humidity.

So this rifle probably would not

have gotten much out of zero, and what I call

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

730

out of zero is maybe an inch or so one way or

the other. If you get real finicky, you make

sure you get it right back on.

So this weapon, if it was in the

condition it was in three some days, four

some days after it was taken into evidence,

literally could not have hit the broadside of

a barn if somebody was shooting with it at a

target.

That brings up some other

circumstances if you want me to go into it

about what I was observing about the target

conditions themselves.

Q. Yes, I'd like like you to briefly

summarize that. Let me also understand what

you have told us now. Based upon your review

of the --

A. You want me to say it simply? In

other words, you buy one of these, put a

scope sight on it, you've got to sight it

in. It takes a bit of doing. It takes a

little help with some mechanical devices on

the front end. That was not done with this

weapon.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

731

It does not appear that this weapon

was sighted in. And when it was recovered

and first taken into evidence, it would not

hit what it was shooting at. It would hit

several feet to either right or left. I

think it was four feet one way and two feet

down.

Q. Yes. That is what the FBI report

indicates?

A. That's right. Anyway --

Q. Could that rifle scope have been

thrown out that amount had it been dropped on

a sidewalk?

A. That amount, no. I had one of these

very scopes, fell out of a tree and landed on

the bloody thing. Damn near broke my leg.

But I could carry on with the hunt.

Q. The scope was intact?

A. Scope was intact. Rugged scope.

That's why they sold a lot of them, the

Redfield two to seven variable. One of the

earlier variables, but a pretty good one.

Q. Let me just ask you: Moving on,

based upon all this analysis and review of

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

732

this rifle, the testing information, the

documentation, is it your opinion that this

weapon was the murder weapon that killed

Martin Luther King, Jr.?

A. Well, I've not discussed the further

ballistics tests I ordered and the result.

But based on the entirety of the record and

the further ballistics tests I had run on

this rifle, it is my opinion this is not the

muder weapon.

Q. Could you just summarize for us the

basis of that opinion?

A. Okay. The basis of that opinion

would be run based on the subsequent

ballistics analysis that was done with this

weapon using scanning electron microscopy to

analyze the sample bullet and compare it with

the slug removed from Dr. King, the

circumstances attendant upon the lack of

similar batch status of the bullets from the

rest the cartridges, this weapon itself in

terms of it not being sighted in and also a

description of the shooting itself in terms

of what supposedly transpired that makes this

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

733

a rather unique weapon.

Now, if you would like, I'll talk

about the ballistics test that I got the

results of.

Q. Yes, please. Go on.

A. Okay. What ultimately happened is I

ordered this rifle thoroughly cleaned for

this reason: It is a new weapon. The bore

has not been shot in. It has not been broken

in. The bores of rifles need to be broken in

just like your car needs to be broken in.

They are still rough.

Remmington was not the worst at

that, but in 1968, 1967, 1966, the firearms

companies were switching over from a lot of

hand labor to machine-manufacturing processes

that had not been perfected. There was a big

hue and cry in the whole gun world about the

defects that you often found with new

products. I know I had to send one back

every four or fifth time I got a hunting

rifle. There was a flaw in it that had to be

sent back for correction.

In any event, I ordered this weapon

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

734

cleaned, because even though it had -- you

can look through it right now. It looks like

you've got a shiny bore. If you look under

it -- at it under certain light conditions,

this whole bore is smeared with jacket

powder. Basically a bullet fired in a

hunting weapon has a lead core. It has a

gilding metal jacket or a bronze jacket, and

there is coating over the top of that.

When you fire it down this bore with

the high heat of the combustion process and

the higher pressure and the velocity, it

leaves trace elements of that jacket all down

the barrel. The more of the barrel that is

broken in and the smoother it gets, the less

it leaves.

When I inspected this weapon

initially, the bore impressed me as quite

filfthy. I used a bore sight. It is a

little device with a light in it. You can

look through this thing. It is absolutely

filfthy.

In any event, I ordered it cleaned.

They apparently did not clean it more than to

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

735

run a patch down one or twice through it. I

had given as a suggestion that they use

something known as a file out, which is a

device made by a company known as Outers,

that is nonintrusive.

You fill this barrel with a

chemical. You put a plug in it, an electrode

in it, hook the barrel up to the other

electrode and you leave it for twenty-four

hours and it works a reverse-plating process

and you get all the filings stripped out of

this barrel and it adheres to the electrode.

So you would have a pristinely-clean

weapon in twenty-four hours. They chose not

to do that but to simply run a patch through

it for a number of reasons, which through

mistake -- which was going against their

mistaken understanding of my order -- they

thought I order them not to clean it.

But in any event, they fired

eighteen bullets from this weapon into a

water tank. Twelve of those bullets, that

is, sixty-six point three four or seven five

or sixty-seven percent, showed a similar

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

736

characteristic that was a very unusual

characteristic.

What usually happens when you take a

bullet and you fire it down a rifle barrel is

that the actual diameter of the bullet, that

is, the .308 in this case, would match the

bore diameter. But when you have the bore,

there are some lands, some ribs that stick

down. Those ribs would engrave the bullet.

They would press markings into the bullet.

What was unusual about the

characteristic of the projectiles that were

fired out of this weapon is that there was a

defect somewhere in this barrel that caused

the bullet not to be pressed down but to come

up into this particular flaw. So what you

did is instead of a rounding, say one of

these styrofoam coffee cups, with grooves

that had been indented in that, imagine, if

you can, that there would be a bump that

would be sticking up on the surface.

So that is very unusual and

indicated that there was some shattering in

the tool that was used to make this barrel.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

737

It very seldom happens. It is very rare.

But it was present on these bullets.

Now, because this weapon was not

cleaned, what happened was that the filing

material was being blown out of this flaw.

So one of these bullets would have a gross

reflection of this flaw. The next shot

through it would be somewhat less impressed

because of the filing that had filled up this

defect. The third one would have even less

of an impression. Then the filing would get

blown out. The next bullets through would

not show it to a gross extent.

So you've got twelve bullets with

the same common characteristic, that is, this

raised area on the surface of the bullet.

There was not -- that was not found on the

corresponding portion of the bullet removed

from Dr. King.

Now, using scanning electron

microscopy, you can get a much more clear

view of what you are looking at than the

traditional method. One of the problems with

the so-called experts that were called in on

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

738

this is none of them were really expert in

much of anything concerning firearms other

than simply looking at one bullet, comparing

it with another bullet, in a microscopic

setting.

None of them had any experience in

scanning electron microscopy, none of them

had any significant experience in actually

shooting or using a rifle or anything other

than what they did in the laboratory.

None of them had ever cleaned a

rifle other than I believe the testimony was

that when they found one clogged with mud or

dirt or debris, they would run a rod through

just to get that out so they didn't destruct

the weapon.

In any event, this characteristic

was common. Sixty-seven percent of the

bullets showed it. I ordered the weapon be

be retested once this cleaning was done. The

nature of the defect was such that it would

be expected that one hundred percent of the

rounds fired would show this defect.

If I can give that to you in lay

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

739

terms, it is like this: You are sixty-seven

years old, seventy-four years, you are having

trouble urinating. You go to the doctor. He

says, I think you need to go see a

proctologist, I'm noting a very hard area in

your -- hard something in your prostate

area. The proctologist says, okay, fine, we

need to run some tests. Every test they run

is saying, okay, you've got prostate cancer.

That's where we are with this rifle

here. The next step would have simply been a

confirmation of everything that had gone

before. But this does not appear to be the

rifle that was used to kill Dr. King.

There is another thing about that

that is unusual, too: The testimony that the

barrel of this rifle was rested across a hard

wood window sill, that the gunman, using one

foot to prop himself up, holding on and using

another arm to hold the weapon, he supposedly

rested this barrel on this window sill and

pulled the trigger.

Well, there is an unusual thing

about this one. Being a slide-action, if you

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

740

do that, nine times out of ten the slide is

going to cycle itself before the pressure is

dropped in the barrel, and what you'll get is

a blown-up or ruptured shell casing, which

will be quite exciting when it happens.

So this rifle fortuitously is

incapable of being used as they indicated in

the proof that was in the record.

So we've got, one, non-similar lots

of components, two, we've got a rifle that

has never been cited in, three, we've got a

usage suggested for that that is impossible

for this particular type of weapon, and then

in addition, when we run the more advanced

ballistic comparison tests, none of that

matches up.

Q. Judge, after all of that analysis,

you had come to order retesting under very

strict guidelines?

A. Very strict.

Q. The cleaning and the retesting. That

was about to go forward. What happened?

A. Well, they removed me from the case.

They said I was biased towards James Earl

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

741

Ray, which found rather astonishing. If

anybody knows me, me being biased in favor of

a self-avowed racist and bigot is absolutely

disgusting as a concept.

What I've always tried to do is be

fair and impartial and neutral and detached

straight down the middle, and sometimes I

know that upsets people when things don't go

as they expect them to go.

Q. So you were removed from the case by

whom?

A. The Tennessee Court of Criminal

Appeals. It is interesting that was done

before a full transcript was developed. I

must say this: That during the course of

these procedings, whenever the prosecution

didn't like what I was doing, they would run

up and file affidavits, which in my personal

opinion misrepresented the state of the

evidence, and they would go up there to get

an emergency stay before a transcript was

prepared.

Now, one thing that struck me as

quite unusual is one of the affidavits they

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

742

filed in this particular case, which was,

quote, the weapon should not be tested

because if it is tested, it may be damaged,

which would prevent it from being tested in

the future, unquote.

Q. Judge, would you explain to the jury

how firing that caliber weapon might generate

what appears to onlookers to be smoke rising

from a brush area?

A. It is my saying you do not get smoke

from smokeless power, but when you have a

high-intensity cartridge like a 30-06, you

don't, but what you might find is the

following: The compression may cause a

condensation of water, which is a phenomenon

that I've observed from time to time hunting

or shooting, or, two, you may kick up fine

dust in the area immediately in front of the

rifle, or, three, because this rifle slug may

be moving close to the speed of sound, the

shock waive from the bullet passing a bush or

some foliage that has dust on it will cause

it to rise and it will look to the onlooker

like smoke.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

743

Now, there is another thing about

this rifle that is of significance. It goes

back to what you asked me in terms of my

opinion about why the .30-caliber weapon.

Not only could you use a number of civilian

weapons, but if somebody were analyze the

basal characteristics of a slug taken from

Dr. King and this weapon with what the FBI

did, you could not tell whether that weapon

came out of an M-14, a M-21, an M-24 or the

Remmington 700 military sniper weapon that

they had at the time, nor could you tell if

it came out of that.

One of the things that they did not

do is attempt to analyze the twist of the

projectile that was recovered which might

have been helpful. But in any event, what

you have is a situation where let's say you

have one, two, three, four or five people who

have been for one reason or the other

convinced that they were doing something

worthwhile, they could have all been out

there attempting to carry out their own

little particular portion in some perceived

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

744

assassination. Meanwhile, other people could

have been involved, and if any of those

people had been out there, then each of the

.30-caliber weapons they possessed could

have been tied into the case just like this

one was.

Q. That fatal shot could have been fired

from any number of .30-caliber weapons?

A. Any number of .30-caliber weapons,

military or civilian. Let's put it this

way: As a professional involved in the

criminal justice system for a very long time,

as a prosecutor, public defender, defense

lawyer handling murders, robberies, very

serious crimes, this had to be one of the

most inept and incapable, if not downright

incompetent investigations, I've ever seen in

my life.

It would it would have struck me

that if they had really wanted to analyze

bullets fired out of this rifle, they would

have fired them into water, not cotton

waste. It would have struck me that they

would have done a more intense analysis of

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

745

what you have over there.

Now, you've got a base of that

bullet that is completely intact, and it is

quite subject to even ordinary ballistic

analysis for striations. They did not do

that.

Q. Judge, on that tack, the FBI reports

indicated that the death slug was too badly

deformed for them to do that kind of

analysis?

A. That's not a badly-deformed slug.

What you have here is an intact base. That

is what you need. What has gone on here is

that most of what is in this record is

something that you would accept on trust.

Ballistics is an arcane subject.

The FBI is supposed to know everything there

is about the subject. In 1996 the FBI was

trusted. The FBI said in our professional

opinion this is not capable of being

analyzed. They didn't do anything on,

absolutely nothing at all, except the worst

things you could do if you wanted to develop

some test results.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999

746

Judge Preston Battle looked at what

they supplied, and even back in 1968 he was

not satisfied with these tests, and ordered

that they be redone. So from 1968 up until

James Earl Ray died, there was a resistance

on the part of local authorities to keep this

weapon from being retested.

The first judge ordered it. I

ordered it. When it was tested, sixty-seven

percent of the bullets were found to not

match that murder slug.

MR. PEPPER: Judge Brown, thank

you very much.

THE WITNESS: You are welcome.

MR. GARRISON: I have no

questions of Judge Brown.

THE COURT: Thank you, Judge.

THE WITNESS: Thank you, Judge.

(Witness excused.)

(Jury out.)

(The proceedings were adjourned

at 4:35 p.m.)

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

(901) 529-1999