992

IN THE CIRCUIT COURT OF SHELBY COUNTY,

TENNESSEE FOR THE THIRTIETH JUDICIAL

DISTRICT AT MEMPHIS

CORETTA SCOTT KING, MARTIN

LUTHER KING, III, BERNICE KING,

DEXTER SCOTT KING and YOLANDA KING,

Plaintiffs,

Vs. Case No. 97242-4 T.D.

LOYD JOWERS and OTHER UNKNOWN

CO-CONSPIRATORS,

Defendants.

TRANSCRIPT OF PROCEEDINGS

November 29, 1999

Volume VIII

Before the Honorable James E. Swearengen,

Division 4, Judge presiding.

DANIEL, DILLINGER, DOMINSKI,

RICHBERGER, WEATHERFORD

COURT REPORTERS

22nd Floor - One Commerce Square

Memphis, Tennessee 38103

(901) 529-1999

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- APPEARANCES -

For the Plaintiffs: DR. WILLIAM PEPPER

Attorney at Law

New York City, New York

For the Defendant:

MR. LEWIS GARRISON

Attorney at Law

Memphis, Tennessee

Reported by:

MS. SARA R. ROGAN

Court Reporter

Daniel, Dillinger,

Dominski, Richberger &

Weatherford

22nd Floor

One Commerce Square

Memphis, Tennessee 38103

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- INDEX -

WITNESS: PAGE

WILLIAM B. HAMBLIN

DIRECT EXAMINATION

BY MR. PEPPER:....................... 998

CROSS-EXAMINATION

BY MR. GARRISON:..................... 1013

REDIRECT EXAMINATION

BY MR. PEPPER:....................... 1015

JAMES JOSEPH ISABEL

DIRECT EXAMINATION

BY MR. PEPPER:....................... 1016

CROSS-EXAMINATION

BY MR. GARRISON:..................... 1024

JERRY WILLIAM RAY

DIRECT EXAMINATION

BY MR. PEPPER:....................... 1026

CROSS-EXAMINATION

BY MR. GARRISON:..................... 1063

WILLIE B. RICHMOND

DIRECT EXAMINATION

BY MR. PEPPER:....................... 1086

CROSS-EXAMINATION

BY MR. GARRISON:..................... 1099

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- INDEX CONTINUED -

WITNESS: PAGE

DOUGLAS VALENTINE

DIRECT EXAMINATION

BY MR. PEPPER:....................... 1101

CROSS-EXAMINATION

BY MR. GARRISON:..................... 1110

REDIRECT EXAMINATION

BY MR. PEPPER:....................... 1110

CARTHEL WEEDEN

DIRECT EXAMINATION

BY MR. PEPPER:....................... 1111

CROSS-EXAMINATION

BY MR. GARRISON:..................... 1120

WALTER E. FAUNTROY

DIRECT EXAMINATION

BY MR. PEPPER:....................... 1123

CROSS-EXAMINATION

BY MR. GARRISON:..................... 1143

REDIRECT EXAMINATION

BY MR. PEPPER:....................... 1148

APRIL R. FERGUSON

DIRECT EXAMINATION

BY MR. PEPPER:....................... 1155

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- INDEX CONTINUED -

WITNESS: PAGE

JAMES E. ADAMS

DIRECT EXAMINATION

BY MR. PEPPER:....................... 1167

CROSS-EXAMINATION

BY MR. GARRISON:..................... 1175

YOLANDA KING

DIRECT EXAMINATION

BY MR. PEPPER:....................... 1177

TRIAL EXHIBITS PAGE

Exhibit 19.......................... 1051

Exhibit 20.......................... 1054

Exhibit 21.......................... 1085

Exhibit 22.......................... 1099

Exhibit 23.......................... 1165

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P R O C E E D I N G S

(Jury in at 10:15 a.m.)

THE COURT: Good morning, ladies

and gentlemen.

THE JURY: Good morning.

THE COURT: It seems that

everyone is all present and accounted for.

Mr. Jowers, the defendant, is still having

some health problems, but we're going to

proceed in his absence. And as soon as he's

able, he'll return. He's still concerned

about the action against him so don't take

this as -- don't interpret it as he's

indicating he's not interested. He is, but

his health is keeping him.

All right. Mr. Pepper, are you

ready to proceed?

MR. PEPPER: Yes, Your Honor.

THE COURT: All right, you may.

MR. PEPPER: Your Honor,

plaintiffs call as their first witness today

Mr. William Hamblin.

WILLIAM B. HAMBLIN,

having been first duly sworn, was examined

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and testified as follows:

DIRECT EXAMINATION

BY MR. PEPPER:

Q. Good morning, Mr. Hamblin.

A. Good morning.

Q. Thank you very much for coming here

this morning. I know you haven't been well.

A. No, a little under the weather.

Q. I appreciate your making the effort

to come by and be with us. Would you please

state your full name and address for the

record?

A. William B. Hamblin, 322 South

Camilla, Apartment 302.

Q. In Memphis?

A. Right.

Q. How long have you lived in Memphis,

Mr. Hamblin?

A. Oh, probably about -- I came here in

'63.

Q. Been here a good number of years?

A. Yes, sir.

Q. And what is your present occupation?

A. I'm a part-time security guard.

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Q. You're a part-time security guard?

A. Yes.

Q. In the city?

A. Yes.

Q. And prior to being a part-time

security guard and taking on that position,

were you -- what else did you do previous to

that?

A. Well, I drove a cab for many years,

and I worked as a barber for approximately

ten years -- something like that.

Q. You were a barber for approximately

ten years and you drove a cab --

A. Right, off and on.

Q. -- off and on for a number of years?

A. Right.

Q. And which company did you drive the

cab for?

A. I drove for Veterans and Yellow.

Q. Both of those cab companies.

A. Right.

Q. Now, in the course of your cab

driving activity and your work there, did you

come to know a cab driver named James McCraw?

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A. Yeah, I knew him well.

Q. And did you in fact share digs or

share rooms with McCraw?

A. Well, I rented him an apartment one

time. I had an apartment house, and I rented

him an apartment. And I lived in the same

apartment building with him a couple other

times.

Q. How long would you say you knew

Mr. McCraw -- over what period of time?

A. Oh, probably about 25 years.

Q. So you knew him over 25 years.

A. Yes, sir.

Q. Did you know him after the date in

question in this case, after the

assassination Dr. Martin Luther King?

A. Yes, sir, I met him after the date.

Q. You met him afterward?

A. Yes.

Q. And you knew him for all of those

years after the assassination?

A. Yeah, it was after the

assassination. I drove a short time before

the assassination, but I wasn't driving at

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the time the assassination happened.

Q. Right. But you new Mr. McCraw during

that period?

A. Right.

Q. Did you not only know him but were

you actually living with him or close to him

in the same building?

A. Well, we shared the same apartment

building more than three times, and he lived

with me a couple of times when he would get

down on his luck.

Q. When he was down on his luck?

A. Yeah. He would lay around on my

couch some.

Q. All right. So it's fair to say that

you were quite a close friend of

Mr. McCraw's?

A. Right, right.

Q. Now, did Mr. McCraw at various times

in the course of this friendship discuss the

assassination of Martin Luther King with you?

A. Yeah, he did.

Q. One time or two times or --

A. Oh, several times.

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Q. Several times.

A. Yeah, several times.

Q. And was he in any particular frame of

mind or condition when this subject would

come up?

A. He would usually be drinking when he

started. I mean, you know, he would start

talking about it.

Q. It was when he had been drinking?

A. Right.

Q. Did he ever volunteer any information

when he had not been drinking?

A. No, he wouldn't talk about it then.

Q. Then he wouldn't talk about it?

A. No, he didn't want to hear about it

then.

Q. And when he had been drinking over

these many times when he spoke with you, did

he tell you a particular story?

A. Yeah. He first come out with

a -- he showed me a story that the National

Inquirer or one of those tabloids did on him,

and they did a pretty good write-up.

Q. And was the story that he told you

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each of these occasions the same? Was it

consistent?

A. It was -- the story he told was

consistent all those years. He didn't vary

off of it.

Q. Over how many years would he have

told you this story consistently?

A. Oh, I probably heard it at least 50

times at least.

Q. For how many years?

A. Oh, now you're trying to pin me down

on dates, and I'm not good at dates.

Q. Not dates, but just roughly.

A. Oh, I would say probably

15 -- something like that.

Q. Over 15 years. And what was the

story that he told you consistently over 15

years?

A. Well, after I got -- after I read the

article and found out that he knew a little

something about it, I got interested in it

myself. And he would talk about Raul having

a drink with him and he --

Q. Did he mention -- let me interrupt

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you and try to focus you. Did he mention the

defendant in this case, Mr. Jowers?

A. Oh, yes.

Q. Did he know Mr. Jowers well?

A. Yeah. He worked for Jowers at the

time I would say. They were both working at

the Southland Cab Company.

Q. They both worked with the same

company?

A. Right.

Q. Did he tell you of his personal

knowledge of any involvement of Mr. Jowers in

the assassination of Doctor King?

A. Yeah, he said that Jowers gave him

the rifle, and he took it and threw it off

the Harahan bridge.

Q. He said that the defendant gave him

the rifle?

A. Right.

Q. And by the rifle, do you mean the

murder weapon? Is that --

A. Right, right. That's the story that

he told.

Q. And he told you this same story over

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the years?

A. Same story over and over. He didn't

vary off of it. And in the last he came up

and I think they changed it to a bullet or

whatever, but I don't remember if he changed

his story or not. But he...

Q. But he consistently told you he gave

him the murder weapon?

A. Right.

Q. Did he say that the defendant made

any admission against his own interest? Did

he say he made any admission when he gave him

the rifle? Did he say anything to him?

A. He said Jowers told him to get it and

get it out of here now. He said that he

grabbed his beer and snatched it out. He had

the rifle rolled up in an oil cloth, and he

leapt out the door and did away with it.

Q. And Jowers told him to get rid of it?

A. Right. That's the story that he

told.

Q. Do you recall when he said that

conversation took place?

A. No, I didn't. To try to pin me down

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on the date, I couldn't.

Q. Right. But would it have been your

understanding sometime near to the

assassination itself?

A. Well, see, I came in on the picture

probably about five years after the

assassination.

Q. Yes. No, I'm not talking about your

conversation with McCraw. I'm talking about

McCraw's conversation with Jowers. Would

that have been around close to the time of

the assassination?

A. Yeah, that's -- the way I understand,

right after it happened. Right after it

happened.

Q. Now, was Mr. McCraw himself fearful

of being charged or indicted?

A. That's the reason they all changed

their stories. Every time they -- McCraw

really wanted to come out with it, but he was

involved in it. And he couldn't really tell

the truth. That's the reason all of them

changed their stories all this time. Their

conscious was getting hurt, and they were in

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fear of being indicted.

Q. Mr. Hamblin, did you tell anyone, in

particular a landlord of yours, that McCraw

knew something about this assassination?

A. Yes, I did.

Q. And was this a landlord in the

premises where both you and McCraw were

living?

A. We were both living at the same time,

right.

Q. And what did you tell to your

landlord?

A. He came by to collect the rent --

Q. Yes.

A. -- and I had introduced him to

McCraw.

Q. Yes.

A. And I told him he was involved in it

in some way and he told us to move.

Q. He told you to move?

A. Right. In fact, he sent the police

up there and harassed us. They locked McCraw

up for having a knife, and we finally wound

up being evicted in about a week.

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Q. So you were evicted by your landlord

because you told him this story?

A. Right.

Q. Mr. Hamblin, who was your landlord?

A. It was Mr. Purdy.

Q. Mr. Purdy.

A. Right.

Q. And what did Mr. Purdy do for a

living?

A. Mr. Purdy was an FBI agent.

Q. So your landlord was an FBI agent?

A. Yeah. I didn't know at the time that

he owned the house. I rented from someone

else, but he happened to be the owner. And

he just bumped in to collect the rent.

Q. But you didn't know that he was the

owner before this?

A. No.

Q. And do you know where Mr. Purdy was

assigned as an FBI agent?

A. Probably Memphis office, Memphis

region.

Q. The Memphis office?

A. Right.

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Q. And he told you to leave?

A. He told us both to move.

Q. Both to move. And did you move?

A. Yeah, about a week later we got

kicked out.

Q. Now, I want to take you back,

Mr. Hamblin, to 1968. What were you doing in

1968 for a living?

A. I was a barber back in '68.

Q. And where did you work as a barber?

A. Cherokee Barber Shop, 2792 Campbell.

Q. Right. And who was the proprietor,

who was the owner of that barber shop?

A. Vernon Jones.

Q. Mr. Vernon Jones.

A. Right.

Q. How long did you work there as a

barber?

A. Oh, I worked for Mr. Jones probably

for about five years all totalled at two

different places.

Q. Is Mr. Jones alive today?

A. No, Mr. Jones passed on some time

ago.

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Q. And were you working as a barber in

that barber shop April 4th, 1968?

A. Yes, I was.

Q. And were you working there

immediately following the assassination?

A. Right. I was working there when they

broke the news about -- oh, I'd say about

6:00 -- 5:30, 6:00 -- something like that.

Q. Now, did you hear Mr. Jones have a

conversation with one of his long-term

customers?

A. Right.

Q. Within -- how soon after the

assassination did this --

A. I would say, oh, probably a week or

ten days.

Q. Within a week or ten days after the

assassination?

A. Yes, sir.

Q. And what did Mr. Jones ask this

long-standing customer?

A. He asked him who did it or who do you

think did it.

Q. Who do you think did it.

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A. Right.

Q. Meaning who killed Martin Luther

King?

A. Right.

Q. And what did this long standing

customer say to him?

A. He told him that the CIA had it done.

Q. That the CIA had it done?

A. Right. That's the answer he gave

him.

Q. How long had this customer been a

customer of Mr. Jones in the Cherokee Barber

Shop?

A. Oh, ever since I worked for him.

Q. How many years roughly would you say?

A. Oh, I'd say probably -- well, I know

of five anyway.

Q. At least five years?

A. Yeah, at least five -- five or six at

the time that I worked for him he had been

coming in.

Q. People often develop close

relationships with barbers and bartenders?

A. Yeah, they'll tell a barber something

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they won't even tell their own psychiatrist.

Q. Was that the kind of relationship

Mr. --

A. Yeah, that's the kind of

relationship.

Q. -- Jones had with this customer?

A. Right.

Q. Who told him the CIA had it done?

A. I mean I didn't hear the conversation

myself. I asked him what he said when he

left after he had told him.

Q. You asked your boss --

A. Mr. Jones what he said.

Q. Right.

A. And he told me.

Q. And that's what he told you.

A. Right.

Q. Would you tell the Court and the jury

who was this long-standing customer?

A. It was Mr. Purdy, the FBI agent.

Q. The same Mr. Purdy?

A. The same Mr. Purdy.

MR. PEPPER: Mr. Hamblin, thank

you very much. No further questions.

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MR. GARRISON: Mr. Hamblin, wait

a minute. I may have a question if you don't

mind.

THE WITNESS: Oh, okay.

CROSS-EXAMINATION

BY MR. GARRISON:

Q. Mr. Hamblin, Mr. McCraw was quite a

heavy drinker, wasn't he?

A. Right.

Q. Alcoholic beverages pretty regular?

A. Right. In fact, he was an alcoholic.

Q. All right, sir. And I believe you

said that you would have trouble believing

him, didn't you?

A. Yeah. I had some trouble believing

him at times, right.

Q. You knew Mr. Jowers, did you not?

A. Right. I worked for Mr. Jowers.

Q. And you never heard him say anything

about any of this, did you?

A. Not really, no, huh-uh.

Q. You said Mr. McCraw would change his

story from time to time when he told it?

A. Well, they was -- what I mean was

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changing the story, they would accuse another

dead policeman.

Q. When you say they, who are they?

A. Well, they first -- they've named

every policeman in the graveyard. Every time

they get scared, they'll name another

policeman as being the murder man.

Q. Are you talking about Mr. McCraw?

A. Well, both of them.

Q. Both of them who?

A. Mr. McCraw and Jowers.

Q. I thought you said you never have

talked to Mr. Jowers about this, never had

anything to --

A. Well, he's made several statements.

Q. Who has? Whose made several

statements?

A. Well, I talked to him -- I talked to

him on the cell phone about six months ago,

me and Millner.

Q. Okay.

A. And he told me that he didn't do it,

but somebody by the name of maybe Earl Clark

or something like that did it, and he did it

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or whatever.

Q. So that's been six months ago?

A. That's here recently.

Q. Did he tell you he didn't have

anything to do with it?

A. That's what he said.

MR. GARRISON: That's all.

Thank you.

THE COURT: All right.

REDIRECT EXAMINATION

BY MR. PEPPER:

Q. Mr. Hamblin, just so that we're

clear, did Mr. McCraw ever change the story

he told you?

A. Never changed his story. He stuck

with the basic same fact -- I took the gun

and threw it off of the Harahan bridge.

Q. So as far as he is concerned -- as

far as you are concerned, the weapon --

A. As far as I'm concerned, that's what

happened. I mean, you know, I believed him

because he stuck to the same story.

Q. So far as you're concerned, the

murder weapon is at the bottom of the

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Mississippi River?

A. That's where I would -- if I was

going to go look for the gun today, I would

go look and look at the middle river bridge

because you can drive right to it. You can

walk 20 feet and drop it and be back in your

car in five seconds and be gone.

MR. PEPPER: Thank you,

Mr. Hamblin. No further questions.

(Witness excused.)

THE COURT: Call your next

witness.

MR. PEPPER: Plaintiffs call

Mr. J.J. Isabel.

JAMES JOSEPH ISABEL,

having been first duly sworn, was examined

and testified as follows:

DIRECT EXAMINATION

BY MR. PEPPER:

Q. Good morning, Mr. Isabel. If you

have trouble hearing me, please just stop me

and I'll speak louder. Thank you very much

for joining us this morning.

A. Yes, sir.

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Q. For the record, would you please

state your full name and address?

A. My name is James Joseph Isabel, 2344

Jackson Avenue, Memphis, Tennessee. Zip

38108-3236.

Q. Thank you, Mr. Isabel. I know you

haven't been well, and we do appreciate you

coming here. You were deposed in this case

on October 14th, and you were kind enough to

answer a range of questions at that time.

And I'm going to put those questions to you

this morning.

A. Okay, sir.

Q. What do you do now for a living,

Mr. Isabel?

A. Well, I'm retired. I'm seventy-four

years old, but I am an independent courier.

I pick up food like for Memphis Hardwood

Flooring five days a week, and I pick up

pagers, take them to get repaired and take

them back to the customer. That's all I do.

Q. And what did you do previously,

Mr. Isabel?

A. Starting which year?

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Q. Let's just go through the range of

jobs and work that you've done, if you can.

Just very quickly try to summarize for us.

A. Well, in '43 I was a sailor in the

Navy in a Pacific killing force, and let's

see, then I got out of the Navy. I went back

to CBHS and got my high school diploma. I

didn't have it before I went in the service,

and then I've driven trucks.

I've driven chartered buses. I

worked for Firestone at one time for six

months, and I worked for Vet cab, Hams --

Mike down at Yellow Cab and then Airport

Limousine. Hams owned Airport Limousine. I

met Jowers at Yellow Cab, and Airport

Limousine, they owned -- Hams might have

owned Airport Limousine, and they owned

something else too. Oh, it went from -- I

think we went from Yellow Cab --

Q. But basically you've done a lot of

driving?

A. Yes, yes.

Q. You drove chartered buses?

A. Right.

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Q. You drove taxi cabs, limousine

service?

A. Yes.

Q. That constituted the main part of

your life, didn't it?

A. A lot of it.

Q. And when did you meet Mr. Jowers as

you said?

A. I met Mr. Jowers at the Yellow Cab.

That was probably in about seventy -- around

'77 I would think.

Q. So you met him when you were involved

with Yellow Cab at the same time?

A. I was working at Yellow Cab with

Airport Limousine and Hams might have hired

Loyd to come down there and run I think the

whole operation or the biggest part of it.

Q. That's around 1977?

A. Yes.

Q. Did you come to know Mr. Jowers

pretty well?

A. Yes, sir.

Q. How often would you see him?

A. Oh, daily.

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Q. You saw him every day?

A. Five days out of seven.

Q. So five out of the seven days in that

period from 1977, you saw him?

A. Right, and sometimes over the

weekends if we had a holiday or something.

We would run the buses from the airport to

Millington.

Q. You saw him then as well?

A. Yes, sir.

Q. So you became quite friendly with

him?

A. Yes.

Q. Did you go on any chartered bus runs

with Mr. Jowers?

A. Yes.

Q. How many did you take with him, do

you recall? If you don't, it's all right,

but roughly?

A. Out of town probably four or five,

and in Memphis, a lot of them -- a lot of

school trips and trips.

Q. I know it's a long time ago and

you've had some medical problems even since

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the deposition.

A. Yes, sir.

Q. So I'm going to try to move you

through your testimony. Did you go on a trip

with Mr. Jowers over one St. Patrick's Day, a

chartered bus trip with him?

A. Yes. Loyd and I took two bus loads

of bowlers to Cleveland, Ohio, and that was

St. Patrick's Day. The reason I remember it,

we were drinking green beer.

Q. Do you remember what year that was?

A. Pardon?

Q. Do you remember the year? Which

St. Patrick's Day?

A. That had to be '79 -- '78 or '79, but

I'm saying '79.

Q. Around 1979?

A. It was winter because Lake Erie was

frozen over.

Q. Right. March 17th, 1979?

A. That's what I'm thinking.

Q. And that trip was to you said

Cleveland?

A. Yes.

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Q. In the course of that trip to

Cleveland, did you share a room with

Mr. Jowers?

A. Yes, sir.

Q. In a local hotel?

A. Yes, sir.

Q. And did you eat with Mr. Jowers?

A. Oh, yes.

Q. Share --

A. Did I eat with him?

Q. Did you eat?

A. Yes.

Q. Did you go to dinner with him? Did

you drink with him?

A. Yes.

Q. Were you together with him most of

the time?

A. Except when he was driving one bus

and I was driving the other one, yes, sir.

We would go to the same destination, and then

we'd usually meet and go and get something to

eat after we took care of the people.

Q. In the course of one evening on that

trip to Cleveland, did you have a discussion

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with Mr. Jowers about the assassination of

Martin Luther King?

A. Yeah, after we had gone and got the

bowlers, we went out and ate down on the

pier, a restaurant down there, and then we

went back to the hotel. And I took a

shower. I don't think Jowers took one then.

I took a shower, and I came out. And he was

sitting on the bed, and I sat down with my

back against the bathroom on the floor. And

for some reason, I just said -- I said, Loyd,

did you drop the hammer on Martin Luther

King. And he just kind of hesitated for a

moment or two, and he said you think you know

I did. I know what I did, but I'll never

admit it or tell it in a court of law. And I

said, oh, and I didn't mention it to him

again after that.

Q. Did you expect that reply?

A. Maybe, yeah.

Q. And when you asked him did you drop

the hammer on Martin Luther King, what were

you asking him?

A. If he fired the shot that killed him.

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Q. And his response again?

A. Pardon?

Q. And what was his response again to

that question?

A. Oh, he said you think you know who

did it, but I know who did it, but I'll never

admit it or tell it in a court of law.

Q. Did you ever raise the subject with

him again?

A. Huh-uh, no.

MR. PEPPER: No further

questions.

CROSS-EXAMINATION

BY MR. GARRISON:

Q. Mr. Isabel, you knew Mr. Jowers quite

well. The two of you were on trips together,

weren't you?

A. Yes, sir.

Q. And this is the only time that

subject ever came up was just the one time;

am I correct, sir?

A. The best I remember.

Q. He never admitted to you or anyone in

your presence he had anything to do with it

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

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or knew anything about it other than this one

time; am I correct, sir?

A. Yes, sir.

Q. All right. And on this time, both of

you were drinking, weren't you?

A. Uh, yes.

Q. You had been drinking a little beer;

am I correct, sir?

A. Well, the best way I can describe it,

I can get high on two beers and I had about

six. And Loyd is a pretty heavy toper. He

can handle it, and I would say he would drink

close to 20 beers or more.

Q. All right. Your question to him was

did you drop the hammer on Dr. Martin Luther

King, and that's your question?

A. Yes.

Q. He simply said you think you know who

did it, but I know who did it and I'll never

admit it. Is that basically what he said?

A. Yes, sir.

Q. But he never said he had anything to

do with it, did he?

A. No.

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Q. That's the only words he ever used --

A. Yes.

Q. -- that he knew who did it? Is that

right, sir?

A. Yes, sir.

MR. GARRISON: Okay. That's

all. Thank you.

MR. PEPPER: Nothing.

THE COURT: All right, sir. You

may stand down. You're free to leave or you

can remain in the courtroom.

THE WITNESS: Thank you.

MR. PEPPER: Thank you.

(Witness excused.)

THE COURT: Next witness.

MR. PEPPER: Your Honor,

plaintiffs call Mr. Jerry Ray to the stand.

JERRY WILLIAM RAY,

having been first duly sworn, was examined

and testified as follows:

DIRECT EXAMINATION

BY MR. PEPPER:

Q. Good morning, Mr. Ray.

A. Good morning.

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Q. Thank you for coming some distance to

be with us today.

A. Yeah, I'm glad to come down.

Q. Would you state your full name and

address for the record, please?

A. My name is Jerry William Ray, brother

of the late James Earl Ray, and I live in

Smart, Tennessee, 107 Short Street.

Q. Mr. Ray, you are the brother of James

Earl Ray?

A. Yes, sir.

Q. Would you just describe for the Court

and the jury the circumstances in which you

were raised and lived as children?

A. We came up real poor during the

depression days. We lived out on the farm

most of the time, and that's when my

brothers -- they had a WPA and he just barely

got by until after the depression. And then

my daddy got a job on the railroad, and then

we were just average people then. But back

during the depression, everybody had it

bad -- anybody who can remember back then.

Q. How many children were there in your

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family?

A. There was nine all together.

Q. And where were you and James in that

constellation?

A. James was the first born, and then

they had a sister Marjorie and John, then I

was the fourth born. We had seven years age

difference.

Q. Seven years --

A. Yes.

Q. -- difference between the two of you?

A. Yes.

Q. And what grade did James go to in

school?

A. I'm not positive what grade. I think

he went to about a year of high school I

think, but I'm not positive of the grade he

went to.

Q. What did he do after that?

A. He went to -- he moved to Alton,

Illinois. See, we lived in a little town

outside of Quincy, Illinois named Ewing,

Missouri, and Alton, Illinois is about 100

miles from Ewing, Missouri. And my uncle

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lived in there and my grandmother lived

there, and they got him a job working at the

Tambery Room. He was fifteen or sixteen.

Q. And he held that job for how long?

A. He held that job -- I forget how long

it was until he went into the Army.

Q. And he had worked up until the time

he went into the Army?

A. Yeah, he worked every day up until

the time he went in the Army.

Q. What do you remember him doing after

he got out of the Army?

A. I don't remember all that much

because he didn't -- he came there a couple

times to visit my mother and my dad. We

lived in Quincy, Illinois. That's where I

was born, and that's where most of our

relatives are from. He come once in a while,

but I didn't see him that much.

Q. Mr. Ray, as you were growing up with

James, did you notice any signs -- obvious

signs of racism or hatred of black people?

A. No. It would be strange to have any

hatred because Ewing, Missouri was just a few

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hundred people, and I didn't never see one

black person in the town. It's just a little

bitty town, and Quincy, Illinois, where I

grew up, they had 42,000 people -- 2,000

blacks and 40,000 whites so I never even went

to school with one. See, and James didn't

either so you can't hate somebody unless you

something -- you know, do something to you.

Q. As he got older though and as you

associated with him, did you see any

hostility toward black people?

A. No, he never did have no hostility

toward any race -- not only blacks, but

Hispanics or anybody. What he tried to do is

live and let live.

Q. Now, he began to get in trouble at

various points in his life?

A. Yeah, after he got out of the Army.

Q. After he got out of the Army. What

was the reason for that? Do you understand

how --

A. No, nobody could understand that

because before he went to the Army, he was a

hard worker. And he went in the Army and

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after he came out of the Army, he just lived

the life of crime after that.

Q. How did he get involved with various

types of petty crimes and small time

criminals?

A. Unlike a lot of the media think, he's

easily -- if he makes friends with somebody,

he's easily led around too, see. And I know

he committed -- he robbed a post office

outside of Quincy, Illinois. This is back in

the fifties, and this Walter Rife was his

name. He's a ringleader. After he got him

to rob this post office -- I mean he's as

guilty as Walter Rife was for doing it, but

then he went on a cash spree. They stole all

his money and he got arrested in Kansas City,

Missouri. Then they sent him to the

Leavenworth Federal Prison.

Q. But where did he meet people like

Walter Rife?

A. He met him in Quincy, Illinois.

Quincy -- it was a real kind of a corrupt

town back in the fifties. They had a

write-up in the magazines about them.

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Everything was open, see -- gambling,

prostitution, everything. And I knew Walter

Rife and I knew his brother, Lonnie Rife, and

like I say, it's a small town. Only got

42,000 people in the town.

Q. Did James tend to hang out in bars?

A. Yeah, on Fifth Street in Quincy,

Illinois. That's where most of the main ones

was at, and then on Third Street, it was a

house of prostitution -- the whole Third

Street. So when you go up to the tavern,

most of the people you run into was pimps,

ex-convicts or something like that.

Q. Well, eventually he was sentenced and

he went away?

A. Yeah, he was sentenced to

Leavenworth, and I think he got out in 1958 I

think -- '58 or '59, and he was sentenced in

there -- I think he did a little bit over two

years in Leavenworth Federal Prison. Then he

got out, and then he met up with a guy named

Owens. Owens, he was an ex-convict and they

did several things. They robbed a Kroger

store, and then he got sent to Jefferson City

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for that.

Q. Do you know where he met Mr. Owens?

A. No, I don't because I wasn't in

St. Louis at that time. I don't know him.

Q. So he was sent to Jefferson City

Penitentiary?

A. Yeah, for 20 -- I think it was for 20

years.

Q. Now, did you visit him when he was in

the penitentiary?

A. I only visited him a couple times. I

didn't visit him much because I was working

up in -- we wrote all the time. I mean every

week we exchanged letters, but when I would

get down in that area, I would visit him.

But I didn't get to visit him that much.

Q. Well, he eventually escaped from

Jefferson City Penitentiary, didn't he?

A. Yes.

Q. He escaped in April of 1967?

A. Yes.

Q. Did you see him after he escaped from

prison?

A. Yeah. Well, I -- see, I didn't know

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he was going to escape, but my other brother

John had visited him the day before he

escaped. And James told him he was going to

escape and for him to come down and pick him

up and which John did. And John brought him

straight to Chicago, and we rented a room at

the Fairview.

I didn't know all this. They rented

the room, then they called me up. John

called me up, and I came in and we all stayed

at the Fairview that night. That's on South

Michigan Avenue in Chicago. So that was how

they escaped. Then after that, John went

back to St. Louis. We used to give James

$100 because he didn't have no money. He

escaped.

So John went back to St. Louis and

James -- and I went back to work the next

day. Then James got a paper and he found an

ad in there at Klinglens (spelled

phonetically) Restaurant in Winnetka, and

Winnetka is only a few miles from where I'm

at. And he went to work there, and we used

to meet every week or so at a bar there in

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

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North Brook, Illinois.

Q. Well, where were you working at the

time?

A. I was working at the Sportsman's

Country Club in North Brook, Illinois.

That's about five or seven miles from where

he was working at.

Q. And you would then see him from time

to time?

A. Yeah, every week or every other week.

Q. Did John have any more contact with

him?

A. No. Once John left us, you know, the

Fairview Hotel in Chicago, he never had no

contact with James until he got back to

Memphis. You know, when he was brought back

from England.

Q. You mean he had no contact with him

from the time he escaped to the time he was

captured?

A. Yeah, the day after James escaped,

John left and went back to St. Louis and I

went out to work. And John didn't ever have

no contact with him after that.

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

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Q. So were you the only family member

who had contact with James?

A. Yeah, the only one. He called me

every once in a while.

Q. During his fugitivity?

A. Yes, sir.

Q. How long did he stay at this job in

Winnetka?

A. Let's see, he stayed there close to

three months.

Q. What did he do after this job?

A. Well, he saved up a few dollars that

he could save up, and he bought an old car.

I think it was a '57 Dodge because he was

talking when he escaped, when John was there

too, when he got out, he had to get out of

the country, see, and he had to leave because

he had all this time to back up. And not

only the 20 years then for escape and

everything. So he told John -- John heard

that too, and he told me, he said I'm going

to try -- I'm going to save up some money and

go to Canada and try to figure out a way to

get out of the country. And so that's what

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

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he did. He saved up. He worked there about

three months and he bought an old junker, old

Dodge. Then I met him the night before he

took off and then he took off and went to

Canada.

Q. Do you recall the date that you met

him before he left for Canada?

A. No, I don't recall. It was about a

day before that he took off for Canada.

Q. Which month was it?

A. That was in July.

Q. Was it --

A. July of '67.

Q. Was it toward the end of July?

A. It was either the middle or late part

of July, and the only reason I know, my

birthday is the 16th, so it was a little bit

after that.

Q. Sometime after that?

A. Yeah.

Q. And he left and went to Canada?

A. And went to Canada.

Q. Did you have any contact with him

when he was in Canada?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

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A. No.

Q. When was the next time you saw or

heard from your brother James?

A. Well, the next time I heard from him

and I can't, you know, quote the days because

I don't keep diaries or nothing, but I guess

it was about six, seven weeks afterwards.

And I think it was in September, probably

late September. He had this pay phone, where

I didn't have no phone in my room.

I worked at the country club where

you get room and board, and we had this pay

phone in the hallway. And he had the

number. That's how you get a hold of me.

Well, he called one day or one evening and

told me to come to Chicago because he knew my

day off. He arrived where so I would have

the day off. He said don't bring your car in

because I'm going to give you my car, and so

then -- so then I took a train.

They had the Northwestern that runs

in down in the loop and he met me down

there. And we spent the night together, had

breakfast together, and he was talking to

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me. And he was all happy and, hell, he was

-- he had plenty of money on him. So he

said I'm going to go down to Birmingham and

buy a late model car. He said you can have

this. He said I'm working now, and he

mentioned Raul.

I can't exactly remember how the

Raul came in. I worked for a guy named

Raul or something like that, but then he

said -- he had a big box of stuff. He said

take this to Union Station -- that's a

railroad station downtown Chicago -- and mail

this down to me at Birmingham and mail it to

Eric S. Galt. He said from now on I'll be

known as Eric S. Galt. And so that's what I

did, and he gave me the car. Then I took him

to the station, and later on I mailed that

stuff down to him as Eric S. Galt.

Q. So he came back from Canada. He had

a job so he told you.

A. He told me he had a job working down

there.

Q. He was working for somebody he met in

Canada?

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

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A. Yeah, and he mentioned his

name -- Raul.

Q. Somebody called Raul?

A. Yeah.

Q. Did he tell you what the job was?

A. No. I knew it was something

illegal. I figured it was dope or car theft

or something. You know, I didn't know what

it was, and I didn't actually care that much,

but I knew it was something illegal because

he was trying -- he said he was working this,

you know, this guy he called Raul to get

enough money so he could get out of the

country, you know, get out of Canada and the

United States totally.

Q. So he was doing -- taking on this

job, whatever it was, so that he could get

out of the country?

A. Yeah, get out of the country.

Q. That was the reason he went to Canada

in the first place?

A. Yeah, and I didn't actually -- I kind

of wish I had of now because, you know, I'd

know more to testify to, but I didn't know

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more about it. But right then I wasn't even

inquisitive because I knew he was doing

something illegal and then met some guy over

there and this guy is paying him to run dope

or whatever he's doing. And I don't even

think half the time he knew what he was doing

because they just had him drop a car off in

Mexico and drop one off in New Orleans.

Q. So after he saw you, you talked with

him in Illinois and he went to Birmingham,

did you have any contact with him over the

course of the next year?

A. Well, up until the time King got

killed, from the time we left Chicago when I

seen him last, he called me three times.

Q. And what did he say on those?

A. It wasn't nothing. It wasn't nothing

but just I'm working or asking how the family

is and this and that. And every call would

be under three minutes because I hear him put

the change in and the operator would never

come on. It would be less than three minutes

each call. So probably -- I probably talked

to him about six, seven minutes since the

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

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last time I met him when he left Chicago

until King got killed.

Q. That's the only contact you had with

him?

A. The only contact I ever had with him

after that.

Q. Have you ever known your brother

James over all the years you knew him when he

was free or when he was inside even --

A. Yeah.

Q. -- did you ever know him to engage in

violence?

A. Never. He never had. He never

had -- the most violent thing he ever did was

rob a store, you know, the Kroger store.

That's the most violent ever, but there never

was no violence used in that, you know. And

in fact, before that he was always, you know,

like a burglar. You know, like breaking in

and stealing money, but then when he got with

that -- I mentioned his name before --

Owens. Owens did robbery, see, so then he

went in on the robbery.

Q. In the course of this time when he

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was on the run after he returned to the

United States and those three phone calls

that you had with him, did he ever mention

Dr. Martin Luther King?

A. No. The King name never came up when

we was in the hotel when we met together and

stayed all night or in no phone calls. The

King name was never mentioned, and the last

thing James was thinking about was, you know,

Jackson or King or Kennedy or any of them

people because he was trying to stay out of

prison.

Q. So there was no mention of them?

A. No.

Q. Was there any mention of any activity

that he was being asked to do related to

Dr. King?

A. No, never nothing.

Q. Now, eventually he went to England,

was extradited and was imprisoned in the

United States?

A. Yes, sir.

Q. Did you have more contact with him

after that?

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A. Oh, yeah, I was coming down here to

Memphis back in '68 when they brought him

back about every week, and I'd drive down and

we'd visit. And what they had -- like Mark

Lane said, he was treated worse than

prisoners of war, you know, the guys they

tried in Nuremberg. He had a TV set on 24

hours a day and the lights. They xeroxed all

of his mail, and they had him on TV all the

time, you know, hooked up. And so when we

would visit, he would have to write me notes

and flash them because otherwise they would

know everything that he knew.

Q. Did he give you the impression that

he was determined to go to trial?

A. He was determined. He was

determined. That's the only thing he wanted

was a trial because he said he'd have to go

to trial. He said only way I can, you know,

convince the people that I'm not guilty and

try to show the people where I'm at was take

a trial. That was the first trouble he had

with his first attorney Haynes because

William Bradford Huie told Haynes that James

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Earl Ray can't take the stand because if he

takes the witness stand, I don't have no

book. So that's when he replaced him.

Q. Well, there was a contractual

relationship between a book writer and his

first lawyer?

A. Yeah, Arthur Haynes went over to

England, the first attorney James had, and he

brought a contract over for him to sign that

he would represent him if he signed that

contract where he'd get all the royalties off

the books, you know. And so then William

Bradford Huie was the one that paid him the

money.

In fact, before he fired Haynes on

November 1st of 1968, I flew down to

Harpersville, Alabama and talked to Huie.

Huie paid my way down there because he wanted

another contact besides the attorney so he

was showing me these contracts, and he's

talking about changing them around where

James would get the money because his idea

was he'd pay your money. He'll even brag

that everybody has got their -- you know,

DANIEL, DILLINGER, DOMINSKI, RICHBERGER, WEATHERFORD

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paid.

And so I told him -- he told me, he

said the only thing is now you go back and

tell James he's not going to take the witness

stand because if he does, I don't have no

book. So I went back and told James you

ought to fire Haynes because Huie is running

the case.

Q. Well, the writer told you that James

shouldn't take the witness stand when he went

to trial?

A. Yeah, that was later on in a -- later

on in a phone conversation with the -- later

on in a conversation with Mark Lane --

Q. Well, we'll come to that

conversation.

A. Yeah.

Q. And in the event, James did not have

a trial?

A. No, he never had no trial.

Q. How did that come about when he was

so determined to have one?

A. Well, what he done when Arthur Haynes

told him he couldn't take the witness stand

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and James said that's the only way I can, you

know -- because he couldn't give these

lawyers like Haynes -- every time you give

him some information, a phone number or

something, he'd give it to Huie. And he said

how can I get a trial when they know

everything I'm going to testify to.

And so when he got rid of Arthur

Haynes, then he got Percy Foreman, and Percy

Foreman came in and said this is going to be

the easiest case I ever had in my life.

There's no evidence at all against him, and

he did that up until about a month before the

guilty plea.

Then he started crying saying

they're going to execute him, they're going

to do this, do this. And so James asked him

to resign from the case because he was

determined to go to trial anyway, and Foreman

wouldn't resign. And Judge Battle said if he

fired Foreman, he had to go to trial with a

public defender.

Q. So the result was that he didn't go

to trial?

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A. No, he didn't go.

Q. He pled guilty?

A. Yeah, Percy Foreman pled him guilty.

Q. I'm going show to you a letter,

Jerry, that was written to James Earl Ray by

Percy Foreman.

(Document passed to witness.)

Q. Take your time, please, and read it.

A. Yeah, I know all about this.

Q. What is the date of --

A. This is May the 9th --

Q. What is the date of that letter?

A. March the 9th, 1969.

Q. March what?

A. 9th.

Q. March 9th, 1969?

A. Yeah.

Q. And when was the guilty plea hearing?

A. Right around that time.

Q. If I may inform them, it was

March 10th. As a matter of fact, it was

March 10th --

A. Yeah.

Q. -- the following day.

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A. Yeah.

Q. And what is the purpose of that

letter from Foreman, his attorney, to James?

What does he tell him there?

A. Well, James told me -- you know, I

went down there when Foreman tried to get him

to plead guilty. And he said he's still, you

know, was fighting against it. He said what

I'll do, I'll have Percy Foreman to give you

$500 before I'll plead guilty. Then you can

go down and get another attorney to reopen

the case in which I used the money, the $500,

I flew down to New Orleans. This is even in

a book because the guy I went down to see

about an attorney, he didn't trust me. He

didn't know what I was coming down there for

so he notified the police and the FBI. And

we met in the park and the police was all out

in the park.

Q. Let's focus on this. This is a

letter from his counsel on the eve of trial,

and this letter offers you -- offers him

$500.

A. Yeah, if --

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Q. Under what conditions was he offered

$500 by --

A. Yeah, if he don't do no -- if he

pleads guilty and don't embarrass him in the

court. That was the agreement.

Q. And that $500 --

A. And he went along with the guilty

plea. He put in a guilty plea.

Q. We understand that $500 was to be

taken to hire a new lawyer to try to set it

aside?

A. Yes.

Q. Was there in fact an application to

set aside that guilty plea shortly

thereafter?

A. As soon as James got to Nashville, he

wrote a letter to Judge Preston Battle and

asked him to take the letter for motion for a

new trial and that Percy Foreman has been

relieved. And when Battle died a few

days -- I don't know, 20 days or whatever it

was after the guilty plea, he had three

letters from James asking for a trial.

MR. PEPPER: Your Honor,

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plaintiffs move admission of this letter.

(Whereupon, the above-mentioned

document was marked as Exhibit 19.)

Q. (BY MR. PEPPER) So he pled guilty and

was sentenced to 99 years. Did there come a

time when you had further contact with

William Bradford Huie?

A. Yes, back in -- I think October I

believe it was of 1977 when James Earl Ray

escaped from Brushy Mountain Prison. His

attorney then was Jack Kershaw, and I

knew -- I had known Mark Lane, an attorney.

And Playboy came out with a dirty story about

my brother so I recommended to James that he

get Mark Lane to represent him. So Mark Lane

took over the case. Just before he escaped,

the trial was supposed to start. That was in

October.

Q. Let me try to move you through to the

point at hand. Did you have a conversation

with William Bradford Huie around that time,

October of 1977?

A. Yes, sir. The day after the escape

trial, I called William Bradford Huie.

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Q. And James had been in prison then for

approximately eight years?

A. Yeah.

Q. And in the course of that

conversation, did Bradford Huie make an offer

to you --

A. He made --

Q. -- to take to James?

A. Yeah, he made an offer, and we got it

on tape. He made an offer that we taped for

$220,000 if I get him in to see James.

Q. Well, he wasn't paying $220,000 for a

visit.

A. No, no.

Q. What was the offer?

A. $220,000 if he would tell him about

killing King and he had to give him, you

know, a story about that he killed King and

that -- he said that's the only way a book

will sell if you write a book that he killed

King.

Q. What would James do with $220,000 if

he was in prison?

A. Well, he said that -- he explained

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that -- he started off with that Blanton was

the governor, and he said we get James out

through Blanton and you and James both can

live good in another country.

Q. So he was going to arrange a pardon?

A. Yes, through Governor Ray Blanton.

Q. Did you record that telephone

conversation?

A. Yeah, it was all taped. Me and Mark

Lane taped it.

Q. And was there a transcription of that

recording?

A. Yes.

Q. Let me show you this transcription.

(Document passed to witness.)

Q. Would you tell the Court and the jury

what is the heading of that transcription,

the date, time and place?

A. It's October 29, 1977, a.m. -- 9:45

a.m. Jerry William -- Jerry Ray or William

Ray, Bradford Huie, Oak Ridge, Tennessee,

rural Scottish Inn.

Q. Would you just look through that

transcription and see if you recognize it as

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the transcription that was made of the tape

recording of that conversation?

A. Yeah, that's it.

MR. PEPPER: Plaintiffs move the

transcription into evidence.

(Whereupon, the above-mentioned

document was marked as Exhibit 20.)

Q. (BY MR. PEPPER) What happened to the

tape of that conversation?

A. Mark Lane made the tape and he turned

the copy over to the House assassination

Committee that was investigating the King

assassination of Kennedy at the time, and he

kept the other one.

Q. So the House Select Committee on

Assassinations had a copy of that tape

recording?

A. Yes, had a copy of it.

Q. That same committee decided that

there was no Raul?

A. Yeah.

Q. Is that right?

A. That's right.

Q. And that in fact James got his money

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that he said Raul gave him from robbing a

particular bank in Alton, Illinois?

A. That's right.

Q. Did James rob that bank in Alton,

Illinois to the best of your knowledge?

A. No. I don't know who robbed that

bank. It's still unsolved. I know they had

claimed that me and James robbed the Bank of

Alton.

Q. They not only claimed that, there was

a front page, column one article in the New

York Times on the 17th of November 1978. I'd

like to show you that article.

(Document passed to witness.)

A. Yeah.

Q. Now, that article claims, does it

not, that the Times investigation, the FBI

investigation and the congressional

investigation all --

A. Yeah.

Q. -- concluded that you and your

brother robbed that bank?

A. Yeah, robbed that bank.

Q. Did you take any steps yourself as a

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result of those charges?

A. Well, what happened was I was in

St. Louis and James was testifying in

Washington in front of the assassination

committee, and they said we're going to prove

you and your brothers robbed the Bank of

Alton and used the money to finance the King

killing. So a friendly reporter there named

James Alber (spelled phonetically) -- Mark

Lane had called him the same day they accused

us when he got a recess from the

assassination committee and asked him to take

me over there and waive the statute of

limitations.

And so Alton, Illinois is only about

20 miles from St. Louis, Missouri. So we

drove over there and we went in the police

station. First, we went in the bank and they

had a different president then. And so then

we went down to the police station and I

turned myself in and waived the statute of

limitation so they could prosecute me. And

they said are you here to confess to the

crime. I said I can't confess to a crime

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that I didn't commit, but I said Congress

accused me of committing a crime so I'm here

to stand trial. He said you never was a

suspect.

Q. The police officials in Alton,

Illinois said you never were a suspect?

A. Never was a suspect.

Q. Did they ever explain to you how this

type of article got written?

A. No, no. They was mystified that, you

know, they even accused me of doing anything,

and so I don't know if it was FBI making

stuff up or where it's coming at. But it

became -- and like I say, I knew I couldn't

have been a suspect because I worked from '65

to '68 in the North Brook -- Sportsman's

Country Club in North Brook. Never was late,

worked six nights a week, never was late or

never missed a day.

Q. Did they tell you that they had been

interviewed by the New York Times?

A. No, they didn't say anything.

Q. There was no reporter from the New

York Times that interviewed them?

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A. Not that I know of.

Q. Did they tell you they had been

interviewed by a House Select Committee

investigator?

A. No.

Q. Did they tell you they had been

interviewed by the FBI?

A. No. As far as that, no, nobody had

ever talked to them about it as far as I know

because they didn't say anything about it to

me.

Q. Yet somehow this appears column one,

New York Times, byline Windell Walls, Junior.

A. Yeah.

Q. 17th of November.

A. See, I don't know if this has

anything to do with it, but in 1981, F. Lee

Bailey had a TV show called Lie Detector on

and they threw me out there. We did two lie

detector tests, and I got tapes of the test

put away. And one, if I was involved in the

King assassination and the one was was I

involved in any bank robberies. And we did

two shows and both showed I was innocent. I

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wasn't involved in no bank robberies or no

Assassinations.

Q. Mr. Ray, let me show you an FBI

air-tel dated on July 19th which supplements

one of 7-26-68, and it has to do with an FBI

review of all fingerprints related to bank

robberies at the time in question.

(Document passed to witness.)

Q. What is the conclusion of the

bureau's analysis of all of the fingerprints

of suspects at that time with respect to

James Earl Ray? This is a comparison of your

brother's fingerprints.

A. According to this, they took

fingerprints and it wasn't his. They

couldn't pick up his fingerprints.

Q. What's the last two or three words?

A. The last -- no identification

effected.

Q. And that was in '68?

A. That was in -- let's see, where is

it? 8-1-68 I think. Yeah, or 8-2-68.

Q. About a year after --

A. The bank was robbed.

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Q. -- the bank was robbed and some nine

years before the allegations again surfaced?

A. Yeah.

Q. Did you testify before the Select

Committee on Assassinations?

A. Yes, I testified.

Q. Did they raise this issue with you?

A. Yeah, they raised the bank robbery.

I couldn't believe it when they raised the

bank robbery. I told them, I said, what, are

you pulling a joke here? I said I've been

over to the bank and the police station and

turned myself in. Oh, we're not playing no

joke he said and so -- but then they

basically got off that bank. And at first,

he started on the banks and the races and all

this other stuff. Every time they had a

different reason the reason he killed King.

Q. Do you know what the House Select

Committee on Assassinations concluded with

respect to whether or not your brother was a

racist when racism was a motive in this

crime?

A. Yeah, even they admit that wasn't

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true, that he wasn't a racist. They went

through his background, our whole family

backgrounds, and they couldn't find nothing

in our backgrounds.

Q. Moving on, Mr. Ray, did it ever occur

to you in the course of your brother's

imprisonment, either to him or to you, to

contact the family of the victim in this

case?

A. I thought about the King family a lot

over the years, and in a way I wanted to, but

James -- I talked to James about it. He said

don't bother them people. He said they've

had, you know -- they've lost that. He said

they're liable to look at you and think

you're the brother of the murderer. He

didn't know how they felt, see, and it wasn't

until he was dying then a lady reporter from

the New York Times called me up. And I don't

remember her name.

And she asked me if I would talk to

the King family if I had a chance, and I said

sure I'd talk to them. And I told her the

same thing. I said if me and James ever

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talked to them, he goes we'd be out of order,

you know, trying to talk to them. And then

this reporter told Dexter or Coretta King

what I said and that's how we got talking

together.

Q. And that's how the communication

started?

A. Yeah, that's how the communication

started.

Q. Were you surprised when they took a

position in support of a trial for your

brother?

A. I was because I knew it was going to

hurt them bad because the government media,

they're going to really come down on them

like they come down on the Ray family. So it

surprised me because I knew for all these

years they've been getting good press, and

all at once, the press is going to turn

against them.

MR. PEPPER: Thank you, Mr. Ray.

THE WITNESS: Thank you.

MR. PEPPER: No further

questions.

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THE COURT: Let's see if

Mr. Garrison has any questions for you.

CROSS-EXAMINATION

BY MR. GARRISON:

Q. Mr. Ray, you and I have talked

previously a few times.

A. Yes, sir.

Q. And you understand we're here trying

to get the truth.

A. Yeah, that's what we're after, the

truth.

Q. Let the chips fall where they may.

You understand that, don't you?

A. Yes.

Q. Let me ask you something. Going back

to the time that your brother escaped from

prison, how long had he been serving then?

How long had he been in the prison there?

A. He had already been in seven years

and he had a 20-year sentence.

Q. And had he made some effort to escape

before this time?

A. Yes, he had tried to escape before.

Two or three times -- I forget exactly.

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Q. Did he ever state to you that he had

any contact or any influence with a warden of

that prison?

A. No, he never did. In fact, like I

said, I only visited him a couple times in

seven years at the prison. And John, I don't

know, my other brother, he visited him maybe

four or five times. But when I went down

there them two times, it was just a friendly

visit.

Q. And when he escaped, you said I

believe that you met him the next day?

A. Yes, sir.

Q. And where was that that you met him?

A. Well, John brought him up. John

picked him up when he escaped and he brought

him to the Fairview Hotel. That's on South

Michigan Avenue in Chicago.

Q. And his plan at that time was to get

a job and then try to get into Canada?

A. Yeah, he -- the next day -- we all

three stayed together that night, and the

next day John drove back to St. Louis and I

went back to North Brook. But before we did,

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we each give him $100.

Q. Okay. Mr. Ray, let me ask you

something. You -- after the assassination,

you talked to your brother I know several

times or at some time to confer with him?

A. Yes, sir.

Q. Did you ever ask him who he thought

did the assassination?

A. Not completely. He knew some way

that they know who done it and that it's

being covered by the FBI, but he didn't know

who done it or why it was done. And

everybody got their own speculations and

that's why even until the day he died, he

fought to get these files released that's

locked up and won't be released for another

30 years. And Clinton said they could be

released, but they still won't release them.

Q. Why are those files sealed for 30

years? Have you been told?

A. Like James said before he died, they

didn't seal them files to protect me.

Q. Who sealed the files?

A. The assassination committee, they had

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them sealed and then I guess with Congress.

Q. Let me ask you, as you know, I've

spent two days taking your brother's

testimony in prison. Did you ever see him

with this person called Raul?

A. No, no, I never -- I only heard him

mention his name one time. That's when he

came back from Canada.

Q. Did you -- did he tell you that Raul

was financing him and helping him?

A. Yeah, he said he was working for

Raul.

Q. What kind of work was he doing for

Raul?

A. I don't know. I knew it was

something illegal. I assumed gun or drugs or

something because he's telling me about

taking them cars to different cities, you

know, and dropping them off so I figured it

was narcotics.

Q. Do you know -- did you have any

discussion with your brother before he

entered a guilty plea? Did you have any

conference with him about that?

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A. Yeah, I came down to visit him. See,

everything we said was taped so you have to

watch what you say and they got the lights

and everything because I didn't want to see

him plead guilty. I knew what struggle he

was on, but he told me too the last time I

seen him he still hadn't made up his mind.

He was still fighting to go to court, and he

told me that Foreman told him if he didn't

plead guilty, they was going to put my dad in

prison which my dad had jumped parole back in

the twenties and was going to charge me as

being an accessory to the murder.

Q. Let me ask you, did you know he was

going to escape before he did?

A. No, I didn't know that. John did. I

didn't.

Q. You had no knowledge?

A. No. I was working up in North

Brook. I was working there like I say six

nights a week.

Q. Did he ever mention to you as to how

he came up with these aliases that he had,

where he got those names from? He had

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several aliases.

A. No, I never did -- I knew a couple of

them -- a Harvey Lomar he used. I grew up

with a guy named Harvey Lomar, a friend of

mine in Quincy, Illinois, but the other one

like the Eric S. Galt and the Ramone Sneyd, I

didn't know how he got them.

Q. Mr. Pepper asked you about the

congressional committee. You testified in

that, didn't you?

A. Yes.

Q. All right. And the conclusion was

that your brother was the one that did the

assassination, wasn't it?

A. I think their conclusion -- if I

remember right, they claimed that he heard of

a $50,000 bounty while he was in the Missouri

prison and he went out and killed King but

didn't pick up the bounty and took off. That

was actually kind of a sad joke. Here you're

going to go out and commit a crime and all

this money spent traveling all over the world

and don't pick up the bounty. Yeah, there's

supposed to have been two guys, Sutherland

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and Kauffmann, in St. Louis supposed to have

been racists that put up the $50,000 bounty,

but they was both dead.

Q. Mr. Ray, had you ever heard anything

about a bounty from someone in Missouri on

Dr. King's life?

A. No. The only thing I heard is what

the assassination committee -- when they came

out, that's the first I heard of it.

Q. Did your brother ever mention to you

that he was ever in a place called Jim's

Grill at any time?

A. No, I don't -- see, the only thing I

can remember, he was telling me about where

he was at at the time that King got killed.

He was at a service station trying to get a

tire fixed, but he never did hardly mention

Jim's Grill to me. I'm not saying he wasn't

in there because I don't know.

Q. Let me ask you this. Did he tell you

that the day this happened that he had gone

up to this rooming house and had registered

as a guest, paid some money? Did he ever

tell you that or did he tell you what he was

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doing there?

A. Oh, yeah, he told me that I think it

was at the DeSoto Motel he had bought this

gun -- was in Birmingham I think it was. And

then he -- then Raul said it was the wrong

one and he had to take it back and get

another one, and he told him to meet him at

that motel in DeSoto. Then he picked the gun

up or Raul picked the gun up that night and

later on told him to rent a room on this

place on Main Street.

Q. Did he tell you that he had gone into

the rooming house and had taken any of his

clothing or personal items?

A. No, I didn't ask him what he brought

in there. I never did -- the only thing I

knew, he went in there and they had -- later

on that night had Raul and another guy in

there. And he said that Raul used his car a

lot, that Mustang, so Raul told him he

wanted to use the car later that time and he

wanted to talk to this guy, you know, by

himself anyway. So James told him, he said

I'll go get the tire fixed. He had a flat

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tire coming in, and that's when he went up to

get the tire fixed.

Q. He spent some time in Atlanta, did he

not, before the assassination?

A. Yeah. He lived in Atlanta. I can't

remember the name of the place he lived at,

but some apartment places in Atlanta.

Q. Okay. Mr. Ray, let me ask you this.

You're aware of the fact that after the

assassination, a map was found that your

brother owned that had a home, business and

another location where Dr. King stayed that

was supposed to be part of his property.

You're aware of that, aren't you?

A. Yeah, I've read that.

Q. Have you ever seen the map?

A. No. The only thing I know is what I

read. I read something that something was

circled -- a church or --

Q. A church and his office I believe was

circled.

A. Yeah.

Q. Did you ever see the Mustang that was

supposed to be driven by your brother -- the

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white Mustang?

A. No. I've never seen it in my life to

this day because I never did see James after

he left Chicago. Then when they took the

Mustang, I think they sold it to somebody

here in Memphis -- a car lot.

Q. After the assassination on April 4th,

1968, when did you hear from your brother

again? Did you talk to him any more after

that, the 4th?

A. No. After -- I can't remember for

sure. I think it was about two months before

the assassination. Then the next time I

talked to him is when they brought him back

from England to Memphis.

Q. So you had not talked to him from the

assassination up until he was brought back?

A. Until he was brought back. And

within a week after he was brought back, I

drove down and visited him.

Q. Did you know where he was during that

time?

A. Oh, no, no. See, the FBI would keep

me in their office all day long after they

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had discovered they was looking for James

Earl Ray. And the FBI, they would take me

downtown. I was working at night and in

there all day because the FBI told me if he

ever gets in touch with you, will you let us

know, and I said you'll know before I know.

Q. Well, did he ever mention anything

about the fact that this Raul had indicated

to him that they wanted to assassinate

Dr. King? Was anything ever said about that?

A. No, no, no. Huh-uh, no. He never

had got involved in anything like that -- no

murder or nothing like that. The only thing

he was trying to do was just make enough

money to get out of the country, and he said

that guy's paying him good.

Q. Mr. Raul was paying him?

A. Yeah. He only mentioned Raul's name

once by name, and right after that he said

he's paying him good. And I believe he was

talking about the same person.

Q. Let me ask you this. Mr. Ray was

never seen anywhere with this Raul that you

know of, was he?

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A. Well, I don't think Mr. Pepper

brought or Attorney Pepper brought this up,

but James sent me down twice -- once right

after the guilty plea. That's what that $500

was for, to go down to New Orleans, because

he'd meet Raul in the Bunny Lounge. That's

on Canal Street.

Q. What was the name of that?

A. The Bunny Lounge -- Bunny lounge.

And it's on Canal Street. And James told me

exactly where it was at, and I went in there

and had two barmaids -- and I mentioned

Raul, you know, like on a friendly term.

Otherwise, you get suspicion and they want to

know what's going on. And the barmaid hadn't

heard of Raul. Then I asked another one

about Randy -- Randy Rosenson because one

time after Raul used a car, when James got

it back, it had a card stuck down in the

side. And on it, it had Randy Rosenson's

name on there and a phone number. And so

then James sent me down again in about '72

and trying to run this guy down. So then

that's when a barmaid said, well, that's

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probably Randolph Rosenson.

So I go back, and James then -- she

says something about he lives in Miami. And

so then I go back in and James had me fly

down to Miami and go to check up on Randolph

Rosenson. They subpoenaed him in front of

the assassination committee, but I don't know

what the outcome was. But anyway, his card

was found in James' Mustang after Raul used

it one time.

Q. When your brother testified before

the assassination committee, were you there

present?

A. No, I was in St. Louis. I watched it

on live TV.

Q. Were you surprised that he entered a

guilty plea?

A. Yeah, I was. I was. I was. Most

people -- I've talked to a lot of people that

in a way don't believe he's guilty, but why

would he plead guilty to something like this

if he didn't do it and --

Q. Did you ever ask him that very

question?

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A. Yeah, well, he kicked himself after

he got out of that place they had him in,

see, and he said that's the worse mistake I

ever made in my life because it's hard to

overturn. But like Mark Lane and them talked

about that.

That was worse where he was at than

the Nazis they put on trial in World War II

after Nuremberg because they had the lights

on, the heat on, they had a policeman in

there with him 24 hours a day and he'd

breathe everything he done. And he couldn't

get no visitors. If he did, he had to write

notes to them unless you wanted the state to

know what he was talking about. Then on top

of that, Foreman said they were going to put

me in prison and put my dad in prison if he

didn't plead guilty.

Q. Did you ever know that your brother

owned a rifle of any type? Did you ever know

of any type rifle he owned?

A. No, huh-uh. He wasn't a good shot

anyway, see, if he shot anything. I think

they classify you when he went in the Army

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and he was a poor shot.

Q. Mr. Ray, was your brother in Los

Angeles some of this time after he escaped

from the Missouri prison?

A. Yeah, he spent time -- I didn't know

about it at the time. I found out later he

was out in L.A. a lot.

Q. But you learned he was in Los Angeles

some of the time?

A. Yeah.

MR. GARRISON: That's all, Your

Honor.

THE COURT: All right.

MR. PEPPER: Nothing further,

Your Honor.

THE COURT: All right. Mr. Ray,

you may stand down. You can remain in the

courtroom or you're free to leave.

THE WITNESS: Okay. Thank you.

(Witness excused.)

THE COURT: At this point we're

going to take break.

(Jury out.)

(Break taken at 11:40 a.m.)

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THE COURT: Let's bring the

jury out, please, sir.

(Jury in at 12:07 p.m.)

THE COURT: Call your next

witness.

MS. AKINS: Good morning, Your

Honor. We have two statements -- FBI

reports, 302's. Both are taken or one taken

April 25th, 1968.

Mr. Ray Alvis Hendrix, Room 14, Fox

Hotel, 106 Vine Street, Memphis Tennessee,

advised that he is employed by the Corps of

Engineers, U.S. Government on the Dredge

Oakerson. Mr. Hendrix stated he worked about

six months in nice weather and is off the

other six months of the year.

Mr. Hendrix stated that on the

evening of April the 4th, 1968, he and Bill

Reed, who resides in Room 4 of this hotel,

ate their dinner at Jim's Grill located at

418 South Main Street, Memphis, Tennessee.

He stated they left the grill at

approximately 5:30 p.m. and slowly walked to

the Fox Hotel. He said they walked on the

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east side of South Main Street.

Mr. Hendrix commented that when they

left Jim's Grill he forgot his jacket and had

to return for the jacket. He said he learned

later that while he was getting his jacket,

Bill Reed looked at a white Mustang that was

parked almost in front of Jim's Grill. He

said he did not notice this Mustang or any

other cars parked in front of Jim's grill.

He stated, however, that when he and

Bill Reed approached the intersection of

Vance and South Main Street, Bill Reed pulled

him back to the curb because the car was

turning the corner. He said this car was a

white Mustang and that after the car turned

the corner Bill Reed commented to him that

this was the Mustang that was parked in front

of Jim's Grill which he looked at while he,

Hendrix, was retrieving his jacket.

Mr. Hendrix stated he did not see

who was in the car but believes there was

only one person. He said he could not

describe him and would not be able to

identify the driver of this car.

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Mr. Hendrix stated that as they were

returning to their rooms or possibly or just

entering their rooms, they heard sirens in

the immediate area and going south on South

Main Street. He said he later learned that

the sirens were from police cars that were

going to the scene of the murder of Martin

Luther King. He said as near as he can

recall, he heard the siren about 6:00 p.m. or

just a few minutes after 6:00 p.m. on

April the 4th, 1968.

Mr. Hendrix stated that the Mustang

had turned the corner and proceeded east on

Vance Street, did not turn the corner very

fast or made the tires squeal. He said he

did not watch which way the Mustang turned or

how far it traveled on Vance Street.

Mr. Hendrix also stated he could not

furnish any information as to the cars parked

or traveling in the immediate area of Jim's

Grill at the time that he and Bill Reed

left. He also stated he could not furnish

any information concerning individuals in the

immediate area of Jim's Grill at the time he

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left to return to his room.

THE COURT: What's Mr. Hendrix's

first name?

MS. AKINS: Ray Alvis Hendrix.

THE COURT: Thank you.

MS. AKINS: Your Honor, the

second statement, also FBI report number 302,

was taken April the 15th, 1968, by

Mr. William Zinny Reed. These are pages 66

and 67.

Room 6, Clark Hotel, 106 Vance

Street, Memphis, advised he is employed as a

salesman for a photography firm and is

currently working in the Memphis area. Mr.

Reed stated that on April the 4th, 1968, he

and Ray Hendrix stopped at Jim's Grill, 418

South Main Street for something to eat. He

said he was in Jim's Grill for some time and

feels that he arrived there at approximately

4:30 p.m. and believes that he left between

5:15 p.m. and 5:30 p.m.

He said when he left, he picked up

his hat and he and Ray Hendrix paid their

check and left Jim's Grill. He said that

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they left the entrance of Jim's Grill and

proceeded north on South Main Street for 10

feet when Ray Hendrix remembered he left his

jacket in Jim's Grill. Mr. Reed stated he

waited in front of Jim's Grill while Hendrix

went back for his jacket.

He commented that while waiting, he

looked and saw a white Mustang was parked

near the entrance of Jim's Grill. Mr. Reed

stated he does not have a car and is in the

market for a car and was considering buying a

Mustang and therefore he looked this car

over. He said he believed the car was an off

white color, that it was not dirty but was

not exactly clean either.

He said he believes this car had not

been recently washed. He said he does not

recall the color of the interior but believes

that it was a dark color. He said he does

not recall seeing anything inside the car

other than five cartons lying on the back

seat. He described these cartons as being

the size of a tin package cigarette carton.

He said these cartons were red and

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white in color, but does not remember any

lettering on the cartons nor does he remember

whether the white or the red was dominant.

He said when he saw these cartons he felt

that the owner of this car was probably a

traveling salesman -- that the owner of this

car was probably a traveling salesman.

Mr. Reed stated he does not know

whether or not any stickers were in the

window of this car and he did not look at the

license. He said he does not recall if the

Mustang had whitewall tires and if it had

wheel covers.

Mr. Reed stated that after Hendrix

obtained his jacket from Jim's Grill, they

proceeded north on South Main and walked on

the east side of South Main Street. He said

when they arrived at the intersection of

Vance and South Main, he was about ready to

walk off the curb when for some unknown

reason he looked around to see if there were

any cars coming. He said as he looked back,

he saw a white Mustang about ready to turn

the corner and go east on Vance from South

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Main Street.

He said he does not know if this is

the same car he saw parked in front of Jim's

Grill but added it seemed to be the same

car. He said he did not see who was in the

car but believes it was a white male with a

white shirt, but does not recall if this

individual had a tie or hat on. He said he

had the impression this person was not young

but was not old. He said he would have no

way of estimating the age of this person.

Mr. Reed said the Mustang proceeded east down

Vance Street. He has no idea where the car

went after it turned the corner.

Mr. Reed stated that he went to his

room and that he had been in his room for

quite some time, possibly as much as 15

minutes when he heard numerous sirens in the

immediate area going down toward Jim's

Grill. He said he learned later that Martin

Luther King had been shot and that the sirens

he heard were from officers going to that

immediate area.

Mr. Reed advised he could not

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furnish any additional information concerning

any cars parked on the street or any people

in that immediate area.

Your Honor, we move that these

statements be marked as plaintiffs' exhibits.

THE COURT: You want to do them

as collective or marked separately?

MS. AKINS: They can be

collective, Your Honor.

THE COURT: Please mark them as

Collective 21.

(Whereupon, the above-mentioned

documents were marked as Collective Exhibit

21.)

THE COURT: Also, ladies and

gentlemen, the new face that you see with

Mr. Pepper and his group is Mr. Dick

Gregory. All right. Call your next witness.

MR. PEPPER: Thank you, Your

Honor. Your Honor, plaintiffs call

Lieutenant Willie B. Richmond.

WILLIE B. RICHMOND,

having been first duly sworn, was examined

and testified as follows:

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DIRECT EXAMINATION

BY MR. PEPPER:

Q. Good afternoon, Mr. Richmond.

A. Good afternoon.

Q. Thank you for joining us here this

afternoon. Would you state your full name

and address for the record, please?

A. Willie B. Richmond.

Q. And your address?

A. 1411 Favell Drive, Memphis,

Tennessee.

Q. What is your present occupation,

Mr. Richmond?

A. I'm retired.

Q. And where were you employed

previously?

A. Memphis Police Department.

Q. And when did you first join the

Memphis Police Department?

A. February the 1st -- February the 2nd,

1965.

Q. Nineteen sixty --

A. Five.

Q. Five. And when did you officially

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retire?

A. April 26, 1997.

Q. So you're a long-standing police

officer?

A. Thirty-two years.

Q. And what was your final rank?

A. Captain.

Q. You reached captain. Now, on the

occasion of the sanitation workers' strike in

February and March and April of 1968, during

those turbulent times, what was your

assignment in the police department?

A. I was assigned to the Internal

Affairs Bureau at that time during the

sanitation strike.

Q. Would you be kind enough just to pull

that mike a little closer to you?

A. (Witness complies.)

Q. You were assigned to internal

affairs?

A. That's correct.

Q. And what did that assignment entail?

What did it mean to be assigned to internal

affairs?

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A. Observe workers to see if any trouble

was going to come up.

Q. Did there come a time when you were

assigned to a surveillance post in the fire

station number two on South Main Street?

A. If that was the one that was at

Calhoun and Main, it was.

MR. PEPPER: All right. Why

don't we just pull that out so we refresh

Captain Richmond's memory.

(Map exhibit set up.)

MR. PEPPER: Permission to

enter, Your Honor?

THE COURT: Yes, sir.

Q. (BY MR. PEPPER) Mr. Richmond, this is

the fire station we're talking about here

(indicating) which is on South Main on the

corner of Butler and South Main. Do you

recognize it?

A. Yeah, that's it. Butler and South

Main.

Q. All right. And where were you on

surveillance duty when you were assigned

here?

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A. I was in the back where the sleeping

quarters is next to Mulberry Street. There's

a sleeping quarters back there.

Q. Back here in the rear of the fire

station?

A. Right.

Q. And where were you looking in

particular during your surveillance duty?

A. I was looking at the parking lot area

to the Lorraine Motel.

Q. But from here across to the Lorraine

Motel?

A. Right.

Q. Do you recall when you started, when

you took up that position first?

A. That particular day, I had gone out

that morning -- but I came back -- to take a

blood test because I was getting married that

coming Sunday.

Q. All right.

A. And I went back down there later on

that evening about maybe 2:30, 3:00.

Q. You came back around 2:30, 3:00?

A. Correct.

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Q. And you then resumed your

surveillance?

A. Correct.

Q. Were you alone or did you have a

partner with you?

A. I had a partner.

Q. And who was that?

A. Detective Redditt.

Q. So the two of you shared that duty?

A. That is correct.

Q. Did there come a time that afternoon

when you were left alone on duty?

A. When I had finished my blood test, I

went back to the office, internal affair's

office, and I was told to go down to the

station to relieve Redditt because he had

been threatened.

Q. So you were told at that point to go

down to the station and relieve him. He was

going to be relieved of responsibility, taken

off?

A. Correct.

Q. And you were going to continue the

surveillance by yourself?

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A. That is correct.

Q. To whom did you report when you were

carrying out this surveillance activity?

A. I called the office and usually I

talked to -- it was then Captain Gerald Ray

or Inspector Time (phonetic), and I can't

remember which one I talked to now.

Q. But you would speak with one of those

two officers?

A. One of the two. Most of the time it

was Ray.

Q. Captain Richmond, let me pass this

report to you.

(Document passed to witness.)

Q. Do you recognize this document?

A. Well, it looks like the statement I

gave on April the 9th, 1968 to Lieutenant

J.D. Hamby.

Q. Right. This is a statement you gave

to Lieutenant J.D. Hamby on April 9th, 1968?

A. That is correct.

Q. Now, this retraces your activity on

this surveillance duty from April 3rd through

the assassination; is that correct?

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A. That is correct.

Q. If you'll turn over to page 2, we're

still on April 3rd. Is there anything of

particular notice or moment that's taken

place on April the 3rd that you can see?

A. No, sir, not in particular.

Q. You see a reference to the Invaders

about midway down that page? Reference to

the Invaders occupying rooms 315 and 316?

A. I see it.

Q. Were the Invaders of particular

interest to you at that time?

A. No, sir.

Q. You were just commenting that they

were there?

A. That's it.

Q. Now, when Dr. King arrived in the

city for that last visit, were you at the

airport?

A. I was.

Q. Did you have a conversation with

anyone connected with either his group or

with the local clergy having to do with

security or protection for him on that last

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visit?

A. I didn't, but my partner did.

Q. Your partner did. Were you present

when that conversation was taking place?

A. I was there.

Q. And with whom was the conversation?

A. I believe he spoke with Reverend

Kyles.

Q. Reverend Samuel Kyles?

A. Right.

Q. And what was the gist of the

conversation with respect to security

protection for Dr. King?

A. At that time we was told that

Dr. King hadn't wanted any police protection.

Q. You were told that Dr. King didn't

want any protection.

A. Police protection.

Q. Any police protection. And this was

told to you in this conversation by Reverend

Kyles?

A. I think it was Reverend Kyles. I'm

not sure, but I believe it was Reverend

Kyles. He was the one that said it I

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believe.

Q. He was the one who said it you

believe?

A. Uh-huh.

Q. Were you familiar with what position

Reverend Kyles held in Dr. King's

organization?

A. No, I was not.

Q. And you didn't know he held no

position in Dr. King's organization?

A. I did not.

Q. If you'll move on to page 3 of your

statement, Captain Richmond, about two-thirds

of the way down the page, do you notice your

note? And I'll read it. "At 2:05 p.m.

Reverend Samuel Kyles arrived and went to

room 307 and departed at 2:23 p.m." You see

that note?

A. Yes.

Q. Do you know who was in room 307 at

that time?

A. Well, at that time, no, I did not.

Q. Let's move on to page 4, please.

A. (Witness complies.)

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Q. The first full paragraph. Would you

read the first full paragraph starting at "at

approximately 5:50 p.m." to us, please?

A. Okay. It says, "Approximately 5:50

p.m., John Smith, Milton Max, Charles Cabbage

and one female colored and approximately six

or seven more of the Invaders opened the door

of their rooms, and I could see them

gathering their belongings. They then

brought them down the stairs and placed them

in the trunk of a light blue Mustang, license

number BL 3750, and they left the motel.

They was going west on Butler to Main."

Q. If I could just interrupt you there.

So at 5:50 p.m., your eye witness recording

sees the Invaders just bustling out of --

hustling out of that motel, leaving the

hotel?

A. They left.

Q. And that's within 11 minutes of the

shooting?

A. Approximately.

Q. Would you continue reading the next

paragraph, please?

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A. "Immediately after the Invaders left,

the Reverend Samuel Kyles came out of room

312 and went to the room where Martin Luther

King was living. He knocked on the door and

Martin Luther King came to the door. They

said a few words between each other and

Reverend Martin Luther King went back into

his room closing the door behind him, and the

Reverend Samuel Kyles remained on the porch."

Q. Right. So you're telling us there

from your eye witness report that Reverend

Kyles knocked on Martin Luther King's door at

about ten minutes to six or shortly after ten

minutes to six, said a few words to Dr. King

after he opened the door. Then when the door

was closed, Dr. King went back into his room

and Reverend Kyles remained on the -- you

call it the porch, but on the balcony?

A. The balcony.

Q. Now, a little further down in the

next paragraph, you record Martin Luther King

coming out onto the balcony. Do you see that

reference there? And if you could read from

the words "at this time the Reverend Martin

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Luther King returned. " Do you see that?

A. I see it.

Q. Would you read that note, please?

Middle of the next paragraph.

A. Okay. "At this time Reverend Martin

Luther King returned from his room to the

gallery and walked up to the handrail. The

Reverend Kyles was standing off to his

right. This was approximately 6 p.m. At

this time I heard a loud sound as if it was a

shot and saw Doctor Martin Luther King fall

back on the handrail and put his hand up to

his head.

At 6:01 p.m., April 4th, 1968, I

reported this to the inspection bureau. I

returned to remain there and keep

surveillance. Also, here now and at the time

I heard the shot, the men of the tact squad

which consists of the sheriff deputy and the

Memphis police department was in the fire

house number four. I immediately hollered to

them I believe that King has been shot.

At this time the men of the tact

squad scramble out of the fire house

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immediately going in all different

directions. Some went to the hotel. Some

went down the street. Later, the fire

department ambulance arrived approximately

five minutes later and departed to the

hospital with Reverend King."

Q. That's fine, you can stop there.

These were your recollections at the time

contemporaneously as you observed what was

going on at the Lorraine; is that right?

A. Correct.

Q. Nowhere in these notes do you record

Reverend Kyles going into Reverend King's

room 45 minutes, an hour before the shooting,

do you?

A. No, I don't.

Q. And if he had done so, is it fair to

say that you would have recorded this entry?

A. I recorded pretty much everything

that went on. I don't have my notebook now,

but we carried little small notebooks.

Q. Right.

A. And I wrote everything down as I saw

it.

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Q. As you saw it?

A. As I saw it.

Q. That was your duty.

A. Correct.

MR. PEPPER: Thank you very

much, Captain Richmond. Plaintiffs move

admission of Captain Richmond's report into

evidence, Your Honor.

THE COURT: All right, 22.

(Whereupon, the above-mentioned

document was marked as Exhibit 22.)

MR. PEPPER: Nothing further.

CROSS-EXAMINATION

BY MR. GARRISON:

Q. Captain Richmond, let me ask you a

couple of questions. I notice on this same

report that you were just reading from you

were asked a question, did you see anything

suspicious, anyone acting boldly, and your

answer was that you did not see anyone acting

with suspicion or anyone that created any

concern to you; am I correct, sir?

A. That is correct. I didn't.

Q. Sir?

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A. I did not.

Q. You also were asked for your

impression of where the shot came from, and

you said it sounded to you like it came from

the northwest side of the fire station toward

the street side?

A. That's exactly where it sounded like

it came from to me.

Q. It sounded like the north/northwest

from the police station? That's what you

said in this report I believe.

A. Yes, uh-huh.

Q. And that's where you thought it came

from at first, isn't it?

A. I have no idea where it came from.

That's what it sounded like to me.

MR. GARRISON: That's all I

have.

MR. PEPPER: Nothing further,

Your Honor.

THE COURT: All right. You may

stand down, sir. You can remain in the

courtroom or you're free to leave.

THE WITNESS: Thank you.

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(Witness excused.)

THE COURT: Do you have a short

witness?

MR. PEPPER: I'm afraid not.

THE COURT: All right. Then

we'll take our lunch break and we'll resume

at 2:00.

(Jury out.)

(Lunch recess taken at 12:35 p.m.)

THE COURT: Bring the jury in,

please.

(Jury in at 2:15 p.m.)

THE COURT: All right. We're

ready to proceed.

MR. PEPPER: Thank you, Your

Honor. Your Honor, plaintiffs call as their

next witness Mr. Douglas Valentine.

DOUGLAS VALENTINE,

having been first duly sworn, was examined

and testified as follows:

DIRECT EXAMINATION

BY MR. PEPPER:

Q. Good afternoon, Mr. Valentine. Thank

you for making this journey, being with us

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this afternoon. Would you please state for

the record your full name and address?

A. My name is Douglas Valentine, and I

live in Longmeadow, Massachusetts.

Q. Thank you. And what do you do for a

living, Mr. Valentine?

A. I'm a writer -- a twice published

writer.

Q. And what is your specialty of writing

and research?

A. The intelligence operations of the

United States Government.

Q. Would you tell us some of the books

that you have written?

A. I've had two books published. The

first was titled The Hotel Tacloban. It was

about my father's experiences as a prisoner

of war in World War II. That book was

published in 1984, '85 and '86. My second

book was called The Phoenix Program, and that

was published in 1990 and 1992.

Q. Would you summarize for us what the

scope and the concern of The Phoenix Program

was?

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A. The Phoenix Program was created by

the CIA in Vietnam in 1967 as part of a

recognition that the war could not be won

militarily and that a second other war had to

be waged against what was called the Vietcong

infrastructure which was a jargon for the

shadow government of the Vietcong.

Q. Now, in the course of your research

and work with respect to the Phoenix Program

and that book, did you come upon information

that has a bearing or is relevant to this

case?

A. Yes, I did. I interviewed hundreds

of people who participated in the Phoenix

Program, including military intelligence

personnel officers and enlisted men who were

assigned to the Phoenix Program in Vietnam.

Some of these military intelligence personnel

upon returning to the United States were

assigned to military intelligence groups in

the Continental United States and began to

conduct surveillance and Phoenix type

operations against anti-war demonstrators and

people in the Civil Rights Movement.

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Q. What was the range of activities that

these groups were involved in?

A. The military intelligence groups

actually had lists of prominent members of

the anti-war movement and the Civil Rights

Movement. Particularly they focused on

Vietnam veterans against the war, but they

had an entire range of targeted individuals

that they surveilled, including such

well-known people as Abbie Hoffman and Jerry

Rubin. But they also acted as agent

provocateurs in demonstrations that would

insight riots at demonstrations in order that

the police could be called in and arrest

individuals.

Q. And break up demonstrations?

A. Break up demonstrations that the

military intelligence personnel had started,

some of the problems that they had started

themselves.

Q. Now, the military intelligence

structure covered the entire Continental

United States, did it not?

A. That's right. There were seven

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military intelligence groups in the

Continental United States spread pretty much

evenly across the country.

Q. And the one that was connected with

this region in the southeast was the 111th

military intelligence group?

A. That's correct.

Q. Was there any particular information

that you happened to come upon with respect

to the 111?

A. Yes, and I included a passage in my

book in The Phoenix Program about that. One

of the intelligence -- military intelligence

individuals who had been in the Phoenix

Program in Vietnam came back to the United

States afterwards and worked in a military

intelligence group -- another one, not the

111. But there was common knowledge within

all of the military intelligence groups about

each other's activities.

And this individual heard a rumor at

the time that the 111th military intelligence

group had been conducting 24-hour a day

surveillance of Martin Luther King and that

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they had actually been in Memphis on April

4th, 1968 and had taken photographs of the

assassination of Martin Luther King.

Q. So the scuttlebutt or the rumor was

that there had been 111th military

intelligence group officers in Memphis at the

time of the assassination in a vantage point

with cameras running?

A. That's right.

Q. And that they actually captured the

assassination on film?

A. That's correct.

Q. Have any of those photographs ever

surfaced to the best of your knowledge?

A. Not to my knowledge.

Q. Did you speak with more than one

source with respect to their existence?

A. No, I did not. I spoke with one

source.

Q. With one source. Now, could you give

us an overview of another intelligence group,

the 902nd military intelligence group and

what you learned about that organization?

A. I thought I knew a lot. I thought I

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knew almost everything about the various

military intelligence groups, but I didn't

learn about the 902nd until 1996 in the

course of researching the book that I'm

writing now which is a book about federal

drug law enforcement. And I did an

individual -- an interview with an individual

named Phillip Manual who in 1975 was a staff

investigator for the Senate Subcommittee on

Permanent Investigations.

And in the course of interviewing

Mr. Manual, I asked him about his background,

and he said he had been in the 902nd military

intelligence group. So in the course of my

interview with him, this was interesting to

me so we temporarily digressed from the

subject that I was interviewing him about and

he explained -- I asked him about the 902nd,

and he refused to discuss the subject. He

said it was a very secret organization and he

had promised not to talk about it.

So I subsequently filed a Freedom of

Information Act request for information about

the 902nd. And I filed that Freedom of

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Information Act request in October of 1996,

and I received a unit history from the United

States Army on the 902nd. And that's --

having read that unit history is basically

the extent of my knowledge of the 902nd.

Q. Right. That was published by the

Department of Defense?

A. By the United States Army, and it was

published in 1994 as a 50-year anniversary

unit history. The 902nd was created in 1944,

and this history was written in 1994 as a

50-year commemorative exercise.

Q. Do you know where the 902nd military

intelligence group was based in 1968?

A. I believe it was based in Washington

D.C.

Q. Do you know that Mr. Phillip Manual

was here in Memphis on April 4th, 1968?

A. I know that, yes.

Q. Do you know what his role was here in

Memphis on April 4, 1968?

A. What I know about his role here, I

gathered from having read Orders to Kill Him

(sic).

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Q. What did you gather was his role?

A. That he had arrived in Memphis I

believe on April 3rd, and on April 4th at

3:00 -- between 3:00 and 4:00 p.m., he met

with a lieutenant from the Memphis Police

Department. And I believe that man's name

was Arkin. And based on what Mr. Manual told

Lieutenant Arkin, Lieutenant Arkin went to

the fire station where a Memphis Police

Department officer named Redditt was

stationed and was observing the Lorraine

Hotel, and Lieutenant Arkin asked that

Mr. Redditt leave his post and return to

police headquarters.

Q. Have you subsequently tried to locate

Mr. Phillip Manual?

A. Yes, I have.

Q. Have you had any success in finding

him?

A. No, I have not.

Q. Any trace of him whatsoever?

A. None whatsoever.

MR. PEPPER: Thank you. Nothing

further, Your Honor.

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CROSS-EXAMINATION

BY MR. GARRISON:

Q. Mr. Valentine, you said at

some -- the 111th was photographing the

assassination? Is that information you

obtained?

A. That's what I was told, yes.

Q. Did anyone ever tell you who the

assassin was? Did they determine that?

A. Nobody ever told me who the assassin

was.

MR. GARRISON: Thank you.

MR. PEPPER: Just one further,

Your Honor.

REDIRECT EXAMINATION

BY MR. PEPPER:

Q. Mr. Valentine, did you ever ascertain

what was the actual vantage point from which

those photographs were taken in your own

investigative work?

A. No, but what I was -- I'm sorry.

Q. From your own personal investigative

work, your own knowledge, did you ever

ascertain that?

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A. No, I did not.

MR. PEPPER: Thank you very

much. Nothing further.

(Witness excused.)

MR. PEPPER: Plaintiffs call

next Mr. Carthel Weeden.

CARTHEL WEEDEN,

having been first duly sworn, was examined

and testified as follows:

DIRECT EXAMINATION

BY MR. PEPPER:

Q. Good afternoon, Mr. Weeden.

A. Good afternoon.

Q. Thank you for joining us here today.

A. Okay.

Q. Would you state for the record,

please, your full name and address?

A. Carthel Weeden, 6732 Tunger Ridge

Drive, Olive Branch, Mississippi.

THE COURT: Could you please

spell Carthel?

A. C A R T H E L.

THE COURT: Thank you, sir.

A. Need me to spell Weeden?

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W E E D E N.

Q. (BY MR. PEPPER) Mr. Weeden, what do

you currently do for a living?

A. I got a little construction company.

Q. Are you basically retired?

A. Well, I am from one job.

Q. What is the job that you're retired

from, Mr. Weeden?

A. Memphis Fire Department.

Q. And when did you join the Memphis

Fire Department?

A. 1951.

Q. When did you retire?

A. July 7, 1982.

Q. That's a long career.

A. Yes, sir.

Q. What was your position from beginning

to end in the Memphis Fire Department?

A. I started as a private. I finished

as a district chief.

Q. So you went all the way --

A. I went all the way through the ranks.

Q. All the way up.

A. Yes, sir.

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Q. And in 1968, where were you

stationed?

A. Fire station number two.

Q. Fire station number two.

A. Main and Butler.

MR. PEPPER: We're going to put

up the graphic just so we fix this location.

(Map exhibit set up.)

THE WITNESS: I guess I'll have

to put on these to be able to see that far.

MR. PEPPER: Your Honor, may I

approach?

THE COURT: You may.

Q. (BY MR. PEPPER) Mr. Weeden, this is

the downtown Mulberry Street/South Main

Street area. Can you see this all right?

A. Yeah, I can see.

Q. And there's the corner of

Butler -- Mulberry, Butler and then South

Main Street (indicating).

A. Yes, sir.

Q. And here of course is the Lorraine

Motel.

A. Yes, sir.

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Q. East of -- and over in here is

Memphis Fire Station number two.

A. Yes, sir.

Q. Is that the fire station where you

were stationed in 1968?

A. Yes, sir.

Q. And what was your position when you

were at that station?

A. Captain.

Q. So you were captain?

A. Yeah, of the station.

Q. Of the station.

A. Yeah.

Q. That means you were the senior --

A. I was senior captain, yeah.

Q. Senior captain and administrative

officer of the station?

A. Right.

Q. Right. Now, these were very

turbulent times in 1968, in early 1968, were

they not?

A. Yes, sir.

Q. Did you have all kinds of police

units and other individuals around the fire

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station?

A. They were in and out, yes.

Q. On April 4th, 1968, the day of the

assassination, were you on duty?

A. Yes, sir.

Q. And on April 4, 1968, were you

approached by two Army officers?

A. That's what they indicated, they were

two Army officers.

Q. And what did they ask you to do?

A. They wanted a look-out vantage for

the Lorraine Hotel.

Q. They wanted a vantage point of the

Lorraine Hotel, these Army officers. And did

you put them somewhere?

A. I put them on the roof of the number

two fire station.

Q. You put these Army officers on the

roof of the number two fire station on the

4th of April, 1968?

A. In the morningtime.

Q. They came in the morningtime?

A. Right.

Q. Did you see them leave?

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A. No, sir.

Q. Did you go up there on the roof with

them?

A. I did.

Q. And were they carrying anything?

A. They had some briefcases or some

items with them, yes.

Q. Did you come to learn what was in

those briefcases?

A. No, sir.

Q. Did they tell you what was in the

briefcases?

A. They said they wanted a vantage point

for doing some photo -- photograph --

Q. Photographic work.

A. Right, right.

Q. So you came to believe that they had

camera equipment in those briefcases, did you

not?

A. Well, that's what they had indicated

to me. I placed them on the roof and then

left.

Q. Approaching again, can you tell us

roughly or exactly on that roof which vantage

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point were they occupying?

A. They was near that -- I guess it

would be the northeast corner there.

Q. The northeast corner of the roof?

A. Yeah. That's where they was placed.

There's a hose tie right there by that.

Q. Right.

A. Yeah, and of course as you approach

up on the roof, you can walk to the edge and

look right down on the street.

Q. So it's a clear vantage point, isn't

it?

A. It's a clear vantage point. There's

a parapet, a wall that was there, but it's

very small. It's about that high

(indicating).

Q. Would anything impede their visual

view --

A. No, sir.

Q. -- their lens view of the Lorraine or

the brush area here?

A. It could all be seen from that

vantage point. It could have been whatever

they wanted to do. It would nothing be in

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it -- keep it from being a vantage point to

do what they had indicated to me they wanted

to watch.

Q. Right. So there would have been

nothing blocking their --

A. No, shouldn't have been at all. But

if I remember correctly, it was a hedge, you

know, there on I guess it would be north of

the fire station in that parking lot area

there. Hedge had been grown up there. Well,

they wasn't very big trees.

Q. But they were above that?

A. Yeah, they were above the fence row

there.

Q. Did you stay with them for any period

of time?

A. No, sir.

Q. You just left them?

A. I placed them at a vantage point that

they seemed to like and left them.

Q. You left them to do their task,

whatever it was?

A. Right.

Q. Did they at the time show you any

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military identification?

A. Well, I'm sure they did or I wouldn't

have carried them up there but I -- you know,

we had a lot of people coming in and out at

that time, you know.

Q. Sure.

A. We was trying to do our best to do

what they wanted to be done.

Q. I'm sure you would. Mr. Weeden, has

any law enforcement officers ever asked you

about that day and what you did?

A. No, sir.

Q. Nobody has ever spoken to you?

A. No, sir.

Q. Does that seem strange to you? You

were the captain of that fire station in such

a critical position.

A. You want me to answer that or just --

Q. You can answer.

A. Yeah. I don't know what to say

except I was there.

Q. And you've never been spoken to about

this?

A. No, sir.

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Q. Did any member of the House Select

Committee on Assassinations, any investigator

for the House Select Committee ever speak to

you about this incident?

A. Not at all.

Q. Any researchers or book writers ever

speak to you about this incident?

A. No, sir.

Q. My, my. Thank you very much,

Mr. Weeden.

MR. PEPPER: Nothing further.

CROSS-EXAMINATION

BY MR. GARRISON:

Q. Mr. Weeden, you had been stationed at

the fire station sometime on April 4, 1968 I

guess; is that correct?

A. Do what, sir? I didn't hear you.

Q. You had been stationed at the fire

station sometime on April the 4th of 1968; is

that correct?

A. At that time I had been there

approximately a couple years.

Q. All right, sir. Had you ever been in

a place called Jim's Grill? Had you ever

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been in that establishment?

A. Not except for maybe an inspection.

We did make, you know, inspections back

then. I think we had had a card on it. I'm

sure I had been in it, but not for any other

purpose.

Q. Had you ever heard the name of

Mr. Jowers mentioned at any time --

A. No, sir.

Q. -- before this occurred?

A. No, sir.

Q. And now, let me ask you something.

You were at the fire station on the day of

the assassination; am I correct, sir?

A. Yes, sir.

Q. In fact, you were over on the balcony

for just a very short time, weren't you?

A. You're talking about that I carried

the guys on the roof?

Q. No, sir. When Dr. King was shot, you

were on the balcony there where he was shot

for just a few moments?

A. I went across to help the ambulance

back up to pick him up.

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Q. In fact, I believe you told me that

you helped put his body onto the stretcher?

A. We did. We loaded him on the

stretcher.

Q. Let me ask you this. When you first

arrived up on the balcony where he had been

shot, was anyone there?

A. Well, there was people around but...

Q. Was anyone trying to do anything for

him?

A. Not as I remember.

Q. Now, did you see the wound where he

was shot?

A. Yes, sir.

Q. All right. You examined it pretty

closely?

A. No, sir, I just...

Q. But you did see the wound where he

had been shot?

A. I did see the wound.

Q. Could you tell, Mr. Weeden, if it

appeared that that wound went up or down in

his area where he was shot?

A. In my opinion, it went up.

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Q. And that's from what you could see

there?

A. Right.

Q. Did you stay there until --

A. Until the ambulance -- we loaded him

up and they carried him away.

MR. GARRISON: That's all.

Thank you.

MR. PEPPER: Nothing further,

Your Honor.

THE COURT: All right. You may

stand down, sir.

(Witness excused.)

THE COURT: Call your next

witness.

MR. PEPPER: Plaintiffs call

Reverend Walter Fauntroy.

WALTER E. FAUNTROY,

having been first duly sworn, was examined

and testified as follows:

DIRECT EXAMINATION

BY MR. PEPPER:

Q. Reverend Fauntroy, thank you for

joining us this afternoon.

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A. Thank you.

Q. Would you state your full name and

address for the record, please?

A. My name is Walter E. Fauntroy. I

live at 4105 17th Street in Washington D.C.

Q. Reverend Fauntroy, would you tell the

Court and the jury of your association with

Martin Luther King, Junior?

A. Well, for the past 40 years I've been

the pastor of my home church in Washington

D.C. Ten of those years was spent as

director of the Washington Bureau of the

Southern Christian Leadership Conference

where I had responsibility for relating to

the agencies of the federal government that

had relevance for our struggle in the decade

of the sixties -- the White House, the

Congress, the Department of Justice in large

measure, and the Interstate Commerce

Commission in the sixties.

The decade of the seventies and

eighties were spent as a member of the

Congress of the United States where, again,

some background of my work with Dr. King in

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organizing the march on Washington in '63 and

the Voting Rights Act March of 1965 and the

Meredith Freedom March from Memphis to

Mississippi to Jackson in '66 had prepared me

for 20 years of working the Congress where my

first goal was to achieve home rule from the

District of Columbia which we were able to

achieve in the year 1974. And thereafter, I

went to work on a second goal which I had in

going to the Congress and that was to have

the House of Representatives investigate the

assassination of Martin Luther King, Junior.

Q. And that became a serious undertaking

of yours, the formation of this

investigation?

A. It certainly did. I had gone through

what we now know to be the infamous counter

intelligence operation that the FBI ran on

Dr. King called Telepro. And I had never

been satisfied that the explanation given for

the assassination of Dr. King, namely, that

one man by himself was able to get out of

jail and follow Dr. King as he did along the

routes which we later traced, shoot him and

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leave Memphis and make his way to Canada and

there get the passports of three persons who

looked like him in route to Southern Rhodesia

to join the militia. It never made since to

me.

And one of my colleagues on the

banking committee, Henry B. Gonzales of

Texas, had the same view with respect to the

assassination of President Kennedy that it

didn't make sense. And we teamed up to

introduce a resolution that called upon the

U.S. House of Representatives establishing a

select committee to investigate those

Assassinations. And I became chair of the

committee investigating Dr. King's

assassination.

Q. So you as a congressman became the

chairman of the subcommittee that dealt with

the King assassination?

A. That's true.

Q. And you chaired that subcommittee

throughout the entirety of the investigation?

A. Without question.

Q. And when did that investigation

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actually begin?

A. As a matter of fact, it didn't get

really under way until six months after the

Congress had authorized it. That because the

staff director of our choice, a prosecutor by

the name Richard Sprague, whom we had

selected because of the excellent work he had

done in Pennsylvania in prosecuting and

bringing about the conviction of Mr.

Fitsimmons who was the president of the

Teamsters who had been accused and then

convicted of having his predecessor killed.

Mr. Sprague was a very thorough prosecutor

and not long after we hired him and he went

to work, there developed a very serious

controversy about his conduct of the initial

days of the investigation that delayed us

about six months.

Q. What was the nature of the conduct of

Dick Sprague that caused controversy?

A. As I recall, it was a disagreement

between him and the chairman of the Full

Committee, Mr. Gonzales, that was resolved by

Mr. Gonzales resigning as the chair and

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Mr. Sprague being dismissed as the chief of

staff.

As I recall, the controversy had to

do with his intent to make available to the

committee all records, not only the FBI, but

the CIA and military intelligence which

became quite controversial for some people,

not for me.

Q. So Dick Sprague wanted to have all of

these files available to the committee --

military intelligence, CIA, FBI records. He

wanted them available for your investigation

and that was met with controversy?

A. It was met with controversy. It

never surfaced as the heart of the

controversy. There seemed to be some

personality problems that, quite frankly, I'm

not competent to deal with with respect to

Mr. Gonzales. But Mr. Gonzales resigned.

Mr. Sprague was fired and Mr. Blakey was

hired and we finally got to work about in

August of that year.

Q. At the time Mr. Sprague was making

his request for these unexpurgated materials,

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was there a media campaign that went on

against him?

A. Quite frankly I can't remember, but I

found him to be a very thorough and affable

person and one who I had looked forward to

giving us the kind of staff direction that I

thought was necessary.

Q. So we're six months down the road and

now you're investigation starts.

A. Yes. I mentioned that because when

we were forced to bring the investigation to

an end -- and the Congress works on two-year

cycles -- we admittedly concluded our

investigation without having thoroughly

investigated all of the evidence that was

apparent.

Q. Why did you conclude the

investigation without looking at all of the

evidence?

A. Because there were not the votes in

the House of Representatives to extend into

the next Congress, an appropriation to allow

us to continue. I think had we had the six

months, we may well have gotten to the bottom

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of everything.

Q. You think you would have done a

better job if you had more time?

A. Oh, without a question, yes. As a

matter of fact, I came away from the

investigation with the view that we had not

explored a number of leads that were apparent

to us. In the first instance, we had not

been able to identify any credible witness

who placed James Earl Ray at the scene. We

had not been able to establish that the gun

which was fired at Dr. King was fired from

the window above, and quite frankly, we had

evidence in my judgment which was credible

from three persons whose views were that the

gunshot came from the bushes below. Nor had

we been able to trace the bullet that entered

Dr. King's body to the gun which had

Mr. Ray's fingerprints on it.

And of course it was almost amusing

when we examined Mr. Ray -- and I sat through

hours of cross-examination of him -- that

Mr. Ray was really competent to be able to

carry out the operation of breaking out of

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jail and traveling around the country and

getting a hold of roughly $10,000 to sustain

himself during that period and of course get

-- there was three passports all by himself

without some help. I was disturbed also

because while he could not hit a target a

hundred feet away with an M-1 rifle, the

marksman or the person who shot Dr. King

obviously was able to do that from about 200

feet away so that these were questions on our

minds.

There was a fellow by the name of

John Paul Speaker who had been suggested as

the person who may have informed Mr. Ray of a

$50,000 offer that had been made to his

brother-in-law, a young man by the name of

Russell Byers, by two men, Kauffmann

and -- John Kauffmann and John Sutherland.

The result of -- we never had a chance to

trace that thoroughly, although the committee

concluded that there may have been a low

level conspiracy since we had not been able

to determine that and we were never able to

get Mr. Speaker to speak.

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And we turned all of that

information over to the FBI with a request to

the Justice Department with a request that

they follow up on those and other deeds that

had many of us with reservations about

closing the investigation.

Q. Were you uncomfortable with the

conclusions of the investigation?

A. I was uncomfortable with the

conclusion that it appeared that James Earl

Ray acted alone, had killed Dr. Martin Luther

King, Junior. I was uncomfortable for

several reasons. One was that we were

never -- I was never satisfied with the

conclusion on whether there was a Raul or

not a Raul. It appeared, as I recall, that

of the $10,000 that -- and that's about

$40,000 now in 1998 (sic) terms. The

$10,000 -- about $7,000 or more of it was

untraceable, and Mr. Ray's testimony had been

that Mr. Raul had given him that money in

return for his gun running as a part of an

underworld operation and so that troubled

me.

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And of course I was troubled with

Mr. Speaker who was at the time or had been

convicted of having killed a person with

malice aforethought and for pay and had spent

only about two or three years in jail.

Q. Wasn't there a consideration by the

committee that Mr. Ray may have gotten the

money from a robbery of a bank in Alton,

Illinois?

A. As a matter of fact, the staff gave

us three possible scenarios. One was that

Ray had received it from Raul, but we had

only evidence -- only evidence you had of the

existence of a Raul was Ray's testimony and

we had no credible evidence at that time that

such a person existed. The second was that

he might have robbed banks during the course

of that period, and we were satisfied that

that was not an option because the FBI had

itself thoroughly researched that and

concluded that there were no known robberies

that Ray could have been associated with.

The third option was that a bank

which he and his brothers robbed in Alton,

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Illinois had been the source of about

$27,000, about nine of which would have gone

to James Earl Ray, but again, we had only

hearsay. There was no conviction or no

judgment that they had in fact robbed the

bank and had been punished therefore.

Q. In fact, isn't it true that the

police chief of Alton, Illinois and the

president of the bank said that the Ray

brothers were never suspects?

A. That is what I heard, and again, not

having the opportunity to investigate and

corroborate a number of statements, we just

didn't have time to finish up.

Q. Since the conclusion of the House

Select Committee's investigation, have you

developed more information of your own

knowledge and have you had further thoughts?

A. I have not developed information on

my own, but I have been impressed with a

number of persons that I consider to be

providing us with scientific and reliable and

objective and verifiable data that would be

worthy of investigation. I was appalled

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quite frankly at reading a book by Mr. Garrow

on the FBI and Martin Luther, Junior, which

detailed in far more graphic terms than we

had come to know in the committee. The

extent of J. Edgar Hoover's hatred for

Dr. King and the determined effort that he

and the FBI made to, quote, remove him from

the scene.

As I recall, we had concluded as a

committee -- well, this is not a conclusion

that I think was written, but our staff

director shared with me -- Mr. Blakey shared

with me the fact that he felt we could

develop a case for negligent homicide against

the FBI in terms of the climate created by

the FBI that made it almost inevitable that

someone would attempt to take his life.

There was a book by a Curt Gentry

written about 1981 which really upset me. It

described -- it was called J. Edgar Hoover

and His Secrets -- the Man and His Secrets.

And it dealt with a connection that he

established between J. Edgar Hoover, Carlos

Marcellas of the Mafia and two Texas business

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people, Kirk -- Clint Merchaser and E.L.

Hunt, which brought to mind particularly the

testimony of a gentleman by the name of

McFerran who had said that he had overheard a

gentleman by the name of Laberto shouting

over the phone that afternoon. You know,

kill him, kill him on the balcony. And I was

really upset about that during the

investigation and had been assured that

really it was just Mr. Laberto's word against

Mr. McFerran's word.

Q. You're saying your committee's staff

assured you that as chairman of that

subcommittee that it was only Mr. Laberto's

word against Mr. McFerran's word and that

there was nothing else?

A. There was nothing to corroborate on

either side.

Q. What they told you --

A. That's what -- that's what we

concluded, and it troubled me as with many

aspects of this case because we had

difficulty finding corroborating evidence of

what seemed on the surface to be the fact. I

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mean anyone who talked with James Earl Ray

knew that he wasn't a rocket scientist and

knew that this level of sophistication could

not have been made available unless he had

had the kind of sophistication that I know

the Mafia has and that our intelligence

agencies have from time to time.

Q. So the intervening years after the

committee concluded its work, issued its

report in 1979, you've maintained an interest

in the case and have continued to read on

your own and digest research that's been

done; is that right?

A. Yes, against the background of having

gone through it with him.

Q. Yes.

A. And I was with him many times when it

was apparent that we were dealing with very

sophisticated forces.

Q. And what was the nature of those

sophisticated forces in terms of their impact

on the movement as you saw it?

A. Well, let me just say this because it

is a point of interest. When I assembled my

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staff and learned about bugging and about

surveillance as its practiced by the FBI, I

took an interest in my own church and my own

phone at home and asked them if they would

not find somebody who could check my phones

out.

And I recall in the sixties one of

my members who worked as a maid offering me a

television set. Well, in the sixties, you

know, I didn't have a television set at the

church so I said I'd like to have one, and

she gave me a television set. That was a

lovely set. It was a black-and-white set.

It stayed in my office throughout the sixties

and even while I was in Congress.

And when the people went through my

office, they found a bug on it that enabled

persons to drive around the block of the

church and pick up anything that was going on

in the church. Well, that was sort of

amusing, but it sort of signaled me what we

joked about a lot in the sixties, namely

that, you know, Uncle Bubba is listening -- I

mean J. Edgar Hoover is listening. So that

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was amusing, and I learned also that there

was a bug in my phone at home that wore out

about three years. A fellow told me it talks

about 500 hours, and I do recall that every

time the phone would get a little funny, I

would call and the same fella would show up

to repair it so those kinds of laughable

things were sort of in my mind.

Q. Formed a pattern?

A. Yes.

Q. Right. Well, Reverend Fauntroy, if

you were uncomfortable at the time of the

conclusion of the investigation after all the

time that's elapsed and all that you've

thought and considered since then, how do you

feel now about the results of that

investigation?

A. Well, of course two things have

really perked my interest, and that was an

article done here in Memphis in the

Commercial Appeal by Stephen Tompkins which

brought a lot of things into focus that I

think would bear thorough investigation

indeed had we known them at the time or had

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any inkling that those things were in fact

even talked about, we would have followed

those leads. The fact that I had never heard

of this 902 group, military intelligence

group here before reading that article.

I had sensed that military

intelligence may have had some surveillance

role on African American leaders over the

years, but what Mr. Tompkins laid out in

terms of the perception by some people in the

country that blacks were ripe for subversion

by the Kaiser, by the communists and that

leadership had been under surveillance like

that, it really perked my interest anew in

whether or not we knew all that happened

before and on April the 4th, 1964 (sic).

Q. The Tompkins article is in evidence

in this case already.

A. Oh, good.

Q. Did your committee ever receive any

information, any evidence at all to consider

with respect to the involvement of military

intelligence and these activities?

A. To my recollection, not at all.

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Q. Did your committee ever receive any

information at all, any records at all,

documents with respect to the involvement of

the Central Intelligent Agency in this

instance?

A. Absolutely not to my recollection.

Q. Did your committee ever receive

unexpurgated files, surveillance and other

files of information from the Federal Bureau

of Investigation with respect to this event?

A. We received so many files from the

FBI, I just -- you'd have to be more

specific.

Q. I'm talking about unexpurgated field

reports with respect to surveillance

activities and --

A. No, no. No indications that

government was paying any more special

attention to Dr. King or our movement or to

my church study.

Q. On your new black and white

television set. Reverend Fauntroy, I mean

this is exactly what prosecutor Dick Sprague

wanted to accomplish for the committee,

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wasn't it, the opening up of these types of

files?

A. Quite frankly, you know, I've never

talked to Mr. Sprague since that time, but I

do know that one of the things that got him

in trouble was that he wanted to open that

whole area up. And there was lot of

publicity about that.

Q. You were chairman of the

subcommittee, Blakey was council Total

Committee. Why was that area not opened up

to the best of your knowledge at this point

in time?

A. Quite frankly, I cannot remember. I

cannot -- I want to -- after reading the

Tompkins article, I wanted to kick myself.

Q. This Court and jury have heard

evidence that there were photographers

surveilling the Lorraine Motel and that

immediate area at the time of the killing,

heard evidence that there was photographic

surveillance in place, military officers.

Did you ever hear anything of that sort?

A. Not at all, and had I heard it,

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believe me, we would have been on that case.

MR. PEPPER: Reverend Fauntroy,

thank you very much. Nothing further.

THE COURT: Cross-exam.

CROSS-EXAMINATION

BY MR. GARRISON:

Q. Let me ask you, Reverend Fauntroy, a

question or two. Do you know what

specifically led the committee to the

conclusion that James Earl Ray was the

assassin and acted alone? Was there anything

specific you recall now that led to this

conclusion?

A. I think the thing that was persuasive

for most members was the number of

contradictions in Mr. Ray's description of

what happened on that day and before with

respect to Raul and with respect to what he

did. I do recall as well that there were

persons who testified that they did not see

Mr. Ray at the gas station, for example, when

the word had been that he had been at the gas

station and others had seen him. The

witnesses who were identified turned out not

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to be credible or denied that they were there

and had what appeared to be credible stories

as to where they were at the time so that the

propensity in the record of Mr. Ray to

contradict himself tended to weigh on the

side of the option that -- there were options

that were given us about Raul and about

where the money came from.

Q. You mentioned about the hatred of the

FBI for Dr. King. What do you recall about

that statement from them?

A. Well, I do remember something that

very much disturbed me, and I was director of

the Washington bureau so I got most of the

information. There were cartoons done after

Dr. King's speech on April the 7th, 1967 --

April the 4th, 1967, a year to the day before

he was killed. There were editorials. There

were cartoons suggesting that Dr. King was a

danger to the American way, that he was an

ally of the communists, that something needed

to be done about him.

It was on the basis of those kinds

of articles that were crafted in the FBI in

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their offices and then fed out to a network

of stations and newspapers that really made

discussion of a December the 23rd, 1963 memo

that had been circulated among FBI personnel

calling them to a meeting to discuss what

they were going to do to remove Martin Luther

King from the national scene. And it was on

the basis of that information that Mr. Blakey

confided with me that a case for negligent

homicide could be developed on the basis of

the evidence we had on what the FBI did to

create a climate and to persuade the public

that Martin Luther King was a danger to the

American way.

Q. You remember specifically anything in

your statements by J. Edgar Hoover that he

made about Dr. King and his work?

A. I certainly do. I remember

statements that resulted. He said that

Dr. King was the most notorious liar in the

country, and that prompted Dr. King, Andy

Young, myself and Ralph Abernathy to have a

meeting with Mr. Hoover in Washington at his

office. And he never answered the question

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why he said it. As a matter of fact, he

spent most of the time explaining to us how

efficient the FBI was and how thorough they

were and how many black people they had

hired, but he never answered that question

and we went away amused. We thought maybe he

thought that we might really go off on him in

the room there, but, no, he never answered

those questions.

Q. Despite of all that, Reverend

Fauntroy, who did the United States

government assign to investigate the

assassination?

A. Well, it is the responsibility of the

federal government of the FBI to do that and

they did. And we took into account all that

they did. One of the things that we -- for

example, we never -- I never knew about James

Russell Byers from the FBI investigation. As

a matter of fact, one of my staffers came

down to Memphis, see, and found it in the

records that this man had said that he had

been offered $50,000 and that he had been in

the habit of taking stolen goods over to a

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hotel here and that two gentlemen, James

Kauffmann -- John Kauffmann and John

Sutherland, had something called fix-a-cold

cough medicine that turned out to be drugs

that they were making. But we found a great

many -- we didn't know about John --

Mr. Speaker, John Paul Speaker, who was

allegedly a cell mate of James Earl Ray and

believed to have suggested to him there was

$50,000 out there for anybody who would

assassinate Martin Luther King, Junior.

Q. Did the committee ever find any

indication that there was a person called

Raul that was in James Earl Ray's life?

A. They never -- we were never able to

establish the existence of a Raul or

corroboration from anybody that a Raul

existed. Jerry and John, James Earl Ray's

brothers, suggested that they knew that their

brother was in touch with somebody that he

called Raul, but it was all hearsay coming

from the brother.

There was some indications -- and I

can't remember the details of it. It sort of

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reminds me of the Jowers case, but there was

a hotel manager in California who recalled

James Earl Ray getting a call on the 27th or

30th of March telling him to go to Birmingham

and that they had -- they had seen this man

before with him, but we never tied that down.

MR. GARRISON: Thank you, sir.

REDIRECT EXAMINATION

BY MR. PEPPER:

Q. Reverend Fauntroy, did you ever see a

photograph -- did your staff ever show you a

photograph of a man whom James Earl Ray

identified as Raul in November of 1978?

A. No, they did not, although I have

seen a photo since then.

Q. Why wouldn't they have shown you that

photograph?

A. You know, I just don't know. It may

well have been that our staff was not aware

of what Mr. Tompkins stated some years

later. It may -- I know that our staff knew

nothing about the Loyd Jowers connection.

Q. Now, I'm just dealing with this Raul

issue.

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A. Yeah.

Q. What I'm getting to with the point of

hindsight and the advantage of hindsight is

the question of how that committee formed

with millions of taxpayers' dollars -- and

I'm taking you really as a prisoner of the

staff of that committee in a sense because

you were chairman. You didn't conduct the

investigation yourself. How the committee

staff could not locate a figure whom James

Earl Ray himself identified only one time

from a photograph that he saw in '78 which

the person 21 years later has been identified

by four other people independently as Raul,

why the staff couldn't do that job or why it

has to be done privately?

A. I wish I could answer that question.

And on hindsight as I said after I've seen

the work of so many scholars who have been

working in these areas, I wish I had known

and I wonder what our staff new.

Q. The other area that interests me is

your recollection of the reaction in the

country to Martin Luther King's speech at

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Riverside on April 4, 1967 when he formally

holds no holds bar opposed the war in

Vietnam. Do you recall what the reaction was

across the land?

A. It was at that point that these

editorials, these cartoons began to appear

around the country and because, again, my

responsibility was for the national office

there in Washington, I got to get regular

versions of the same editorial -- this man is

dangerous and regular caricatures of a man

whom I considered the singularly most

important man with a most important message

for this, the most violent century in the

history of mankind. It was we've got to

learn to live together as brothers, and so it

hurt me.

And the effect of it was their

organization found many of its supporters

refusing thereafter to contribute to our

effort, and I do remember one call that I'll

never forget from Dr. King at a time when he

was very discouraged about what had happened

because he had taken a position that

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conscious told him was right. And it was on

an evening when I was just finishing up a

sermon for the next day and quoted to him an

English Methodist preacher who said on some

issues, cowards ask the question is it safe

to take a position, and expediency asks the

question is it politics, and vanity asks the

question is it popular, but conscious always

asks the question is it right.

And I said to Martin there are some

things you have to do not because they're

popular or politics but because they are

right, and I think that sort of helped him

through that period and we survived it.

Q. Was there a similar reaction of fear

with the announcement of the march on

Washington, the one that was planned in

April -- not April but in the spring of '68,

the poor people's campaign?

A. Yes, but I tell you, I was shocked by

the killing. I was shocked because we had

lived for about a decade to that time with

threats to Dr. King on his life. In fact, in

New York City, he had been stabbed by a

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demented woman, but it had become sort of

routine just to dismiss those kinds of

threats. It just never occurred to me that

the prospect of our doing not a one-day march

on Washington, but as Dr. King promised, a

demonstration that would last until this

nation ended a war in Vietnam and got serious

about the war on poverty. So that there was

talk about the risks, but really that was not

the question.

The question for us was whether or

not there might be provocateurs who would

deliberately start things, and quite frankly,

the reason we came back to Memphis was

precisely because we feared that if we did

not settle it here and make it very clear

that we were not going to brook any violence

as a part of our demonstration in Washington,

that we might not be able to carry it out

because Dr. King was determined that we're

not going to have a demonstration that

degenerates into violence.

Q. Lastly, Reverend Fauntroy, did there

come a time in 1977 when you became aware of

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a threat on James Earl Ray's life?

A. Oh, certainly. In 1977, not long

after we had gotten into the investigation in

earnest, we heard that Mr. Ray had broken out

of the prison here in Tennessee.

Q. Brushy Mountain Penitentiary?

A. Yes, which was very troubling because

I was afraid that perhaps persons who feared

he was telling the truth might want to take

his life. As a matter of fact, we were so

concerned about it that a former colleague of

mine in my first year of the Congress, Ray

Blanton, had left Congress and had become

governor of this state, and I suggested to

our chairman, Mr. Stokes, that we call him

and ask him that he make sure that every

effort was being made by the state to capture

Mr. Ray before some people from the FBI who

were reported to us to be down here on a

state matter.

Q. And in fact, weren't there upwards of

30 FBI SWAT team snipers that descended on

this state as soon as Ray escaped?

A. I don't know that. I have no

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evidence, but that's what we heard and that

alarmed us. And we called Mr. Blanton and my

information is that he acted and the FBI was

asked to leave and Mr. Ray was recaptured and

we all breathed a sigh of relief.

Q. Yes.

MR. PEPPER: Unfortunately

nothing further. Thank you very much.

THE COURT: All right. Thank

you. You can stand down or you can remain in

the courtroom or you're free leave.

(Witness excused.)

THE COURT: Let's take our break

now.

(Jury out.)

(Break taken at 3:23 p.m.)

THE COURT: Bring the jury out,

please, sir.

(Jury in at 3:53 p.m.)

THE COURT: Mr. Pepper.

MR. PEPPER: Thank you, Your

Honor. Plaintiffs call Ms. April Ferguson.

APRIL R. FERGUSON,

having been first duly sworn, was examined

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and testified as follows:

DIRECT EXAMINATION

BY MR. PEPPER:

Q. Good afternoon, Ms. Ferguson.

A. Good afternoon.

Q. Thank you very much for joining us

this afternoon.

A. Thank you.

Q. Would you state your full name and

address for the record, please?

A. April R. Ferguson. I live in

Memphis, Tennessee.

Q. What do you do for a living?

A. I'm an attorney.

Q. And how long have you been an

attorney?

A. About 21 years.

Q. Were you an attorney in 1978?

A. I had just been admitted to the bar.

Q. Were you a part -- at that time were

you a part of the James Earl Ray defense

team?

A. I'm sorry?

Q. Were you a part of James Earl Ray's

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defense team at that time?

A. Well, it was a post conviction

attempt to gain him a new trial, and I was

working with Mark Lane and Charles Galbreath

who was a retired judge in Nashville.

Q. In the course of that work, back in

1978 in the effort to seek a trial for

Mr. Ray, did there come a time when you

received a communication from an inmate who

was housed in the county jail?

A. Yes. Actually my memory of that is

necessarily unclear after all these years,

and I do have an affidavit that I had

prepared at that time that you have provided

me with if I could use that to refresh my

memory.

Q. Yes, if it's all right with the

Court.

THE COURT: You may, yes.

A. Thank you. Our office received a

call. It was directed to Mr. Lane. The

party asked for Mr. Lane, and I spoke to him

on January 30th, 1979. And he called several

times asking for Mr. Lane, and Mr. Lane was

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traveling. So he asked that someone from the

office come to see him so I got permission

from his attorney to visit him and did go

with our secretary to visit him in the jail

downtown here in Memphis -- that was the old

jail -- on January 31st, 1979. His name was

William Kirk, K I R K.

Q. And what did -- when you went to

visit Mr. Kirk, what did he tell you?

A. Well, we asked if we could tape

record our conversation. He would not allow

us to do that, and he also asked that we not

use his name. But of course we had his name,

and the secretary and I both took notes. Her

name was Barbara Rabbito, R A B B I T O. He

told us that he'd been in the Shelby County

Jail from 1972 until the time we interviewed

him on robbery and extortion charges, and in

August 1976, he was on furlough from the

Missouri Penitentiary for armed robbery. He

was arrested in Memphis on another charge and

unable to bond out, and he started serving

his sentence in the Shelby County Jail. And

then between October 1976 and February of '77

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in the Shelby County Jail, he had met a

person named Arthur Baldwin whose name at

that time was quite well-known to Memphians.

I don't know if it is anymore.

Q. How was Mr. Baldwin's name

well-known?

A. My own personal recollection of

Mr. Baldwin is that he was the owner of

several clubs where there were girl dancers.

I don't remember if there was gambling or

anything like that. I just remember that

that was what Mr. Baldwin was known for.

Q. Okay. So he said he was contacted --

this inmate, William Kirk, said he was

contacted by Mr. Baldwin?

A. Well, he had met him, and then

Mr. Baldwin was apparently serving a sentence

for some kind of non-violent crime like

income tax evasion or he didn't know really

what it was, but he said Baldwin had already

talked to -- and I don't know how he knew

this -- to Mr. Kirk's codefendants. And

these also were names that were known to

Memphians or to me anyway -- Albert Tiller

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and George Tiller. I think they were called

the terrible Tiller brothers by a lot of

people.

And apparently Mr. Baldwin had

offered them $2,500 to do a job stopping

somebody from attending a board meeting.

Then the job was offered to Mr. Kirk, and

Mr. Kirk didn't say whether he took that job

or not. But he did say he and Mr. Baldwin

were friends, that he had saved him from some

sort of unpleasantness in the jail. He also

told us that in June 1977 he was released,

but then he was arrested two weeks later for

a robbery in Germantown. He got out again

and he stayed out until November of 1977

where he was arrested in Jackson, Tennessee

and brought back to Memphis, was released

again in December.

Then he went and started visiting

Mr. Baldwin at his place of business when Mr.

Baldwin had been released, and then he said

he was offered a murder contract by

Mr. Baldwin for $5,000, and he was told that

there were three more pieces of business in

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Memphis for larger sums of money. And Kirk

told us that he didn't take the murder

contract and was back in jail when it was

carried out against a person named David

Macnamee (spelled phonetically) in Memphis.

And he further related that Baldwin was from

the state of Washington and that he had been

in the Memphis area since '75 or '76.

Then Kirk had to go back to Missouri

on a warrant. Then he came back to Tennessee

in March of 1978, and in September of '78, he

was sentenced to 65 years on the various

cases he was facing in Tennessee. But in

June or July of 1978, he had a telephone

conversation with Mr. Baldwin during which

time Baldwin mentioned another murder

contract for $5,000. This time with James

Earl Ray as the target, and my recollection

is that Mr. Ray was then at Brushy Mountain,

but I'm not absolutely sure.

Q. Yes, I think that's right.

A. And Kirk said to us that he didn't

know if he was being offered the contract so

much as just being told that the word needs

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to get out that this contract is available.

Q. This was a contract on James Earl

Ray's life?

A. Yes.

Q. And the contract was put out by the

same Arthur Baldwin?

A. Well, it's unclear from what Mr. Kirk

told us as to who was really letting out the

contract. You know, whether it was Baldwin

or somebody else.

Q. Baldwin was communicating it in any

event?

A. Baldwin communicated it.

Q. It wasn't clear where it was coming

from?

A. Right.

Q. Right. Kirk became apprehensive

about carrying out this contract, did he?

A. He didn't. He was not in a position

at that time to take it up. I mean he was

not in that facility. He didn't indicate

that he was interested in taking it up.

Well, I think he did say later that he didn't

want to. He had heard from those who had

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been at Brushy Mountain that James Earl Ray

was, quote, good people, closed quote, and

there was no need to kill him. He therefore

decided to tell Ray's attorney, and that

would have been at that time either Mr. Lane

or Mr. Galbreath.

Q. Right.

A. He -- Mr. Kirk got the impression

that Mr. Baldwin was working as an agent or

informer for the federal government. He

didn't say how he got that impression except

that it later turned out that Mr. Baldwin was

responsible somewhat for the exposure of

Governor Ray Blanton and his pay for pardon

scandal. I don't think you were here when

Governor Blanton left office early.

Q. Right.

A. So Kirk while he was out of jail

visited Baldwin frequently and was surprised

that although Baldwin had a comfortable home

here in Memphis, they frequently went to the

Executive Plaza Inn near the airport for

meetings, and it was his impression that

Mr. Baldwin was helping the federal

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government in their investigation and that he

was being protected by the federal government

for being prosecuted for state violations of

the law, although he wasn't clear what those

violations were. And he was afraid -- Kirk

was afraid that this assassination plan of

Mr. Ray had originated with the federal

government, but he didn't tell us any sources

for that.

Q. Well, he did indicate and you

indicate in the affidavit that Baldwin

operated occasionally from rooms at the

Executive Plaza Inn near the airport?

A. Yes.

Q. Do you recall whether he said

that -- whether Kirk said that the phone

call -- and this was communicated by

telephone, wasn't it, this last offer?

A. Well, he just says -- yes, in June or

July of 1978. When we talked to him, I

recall that he was in a jail cell, and he had

no papers or memoranda or anything with him

so I don't know how...

Q. Just giving you this recollection?

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A. Yes. I don't know how accurate he

was.

Q. But in any event, he thought -- he

had the impression that this contract on

James Earl Ray's life had originated with the

federal government?

A. Well, he knew that Mr. Baldwin had

already been working for the federal

government so it's hard to say. That was

just his impression.

Q. That was his impression.

A. And I honestly can't recall -- it's

only through looking at this affidavit that I

can recall these details because I recall the

visit. I recall going there with Ms.

Rabbito, and then I recall preparing this

affidavit so we could recall what was said.

But beyond that -- I don't recall being

allowed to do any follow-up. I don't think

he wanted to speak to us anymore.

Q. You don't recall hearing anything

more about this?

A. Oh, certainly Mr. Kirk became

notorious --

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Q. Yes.

A. -- for other things later but..

Q. But not this?

A. We weren't able to follow-up on this

anymore.

Q. All right. Ms. Ferguson, let me just

show you this copy of the affidavit and ask

you to look at it and compare it. This is

dated the 16th day of February 1979.

(Document passed to witness.)

A. For some reason it's got two page 5's

on it that are identical, but that is what I

recollect -- that's a copy of what I have.

This is exactly the same as what I've been

looking at.

Q. Do you recognize your signature on

that?

A. Oh, I see. It's not two pages. Yes,

it's my signature.

MR. PEPPER: Move to admit, Your

Honor.

THE COURT: All right.

(Whereupon, the above-mentioned

document was marked as Exhibit 23.)

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Q. (BY MR. PEPPER) Did you ever hear

anything more about this contract that

Mr. Kirk told you Mr. Baldwin had given to

him?

A. I may have, but so many years have

passed since that subject was pursued and so

many bits and pieces of information were

gathered together and then we weren't able to

pursue them that we would put a little piece

here, put it down and file it away and then

not be able to follow-up on it. I do recall

that when Mr. Kirk made a spectacular escape

from one of the Tennessee facilities that I

recalled who he was then, but I personally

can't recall what follow-up, if any, was

done.

Q. This section of plaintiffs' case is

dealing with cover up. One series of

activities of cover up happened to be

assassination, killing, a murdering of

people. That's why this is important.

A. Thank you.

Q. At that point in time you were

involved. Where is Ms. Rabbito today, do you

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know?

A. I wish I knew. She moved to Northern

California. I heard she was planning a

marriage, but beyond that, I don't know. I

lost track.

MR. PEPPER: Okay. Thank you

very much.

THE WITNESS: Thank you.

MR. PEPPER: Nothing further.

MR. GARRISON: I have no

questions, Your Honor.

THE COURT: All right. You may

stand down.

(Witness excused.)

MR. PEPPER: Plaintiffs call

Mr. Jimmy Adams, Your Honor.

JAMES E. ADAMS,

having been first duly sworn, was examined

and testified as follows:

DIRECT EXAMINATION

BY MR. PEPPER:

Q. Good afternoon, Mr. Adams.

A. How are you doing?

Q. Thank you very much for joining us

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here today. Would you state your name and

address for the record, please?

A. James E. Adams, 168 Shamrock in

Arkansas.

Q. Thank you. And what do you do for a

living?

A. I drive a cab.

Q. Your testimony is in a portion of the

plaintiffs' case that deals with cover

up -- various aspects of cover up. How long

have you been driving a taxi cab in Memphis?

A. Since 1966.

Q. Have you driven consistently from

that period to now?

A. Yes, sir.

Q. You've had a long history of driving

a cab?

A. (Witness nods head.)

Q. Are you familiar with the defendant

in this action, Mr. Loyd Jowers?

A. Fairly. I mean I know of him, yes.

That's about it. I knew he was in the cab

business a lot.

Q. You knew he was in the cab business

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for quite a period of time?

A. Yeah.

Q. Which company do you drive for now?

A. I drive for Yellow Cab Company.

Q. For Yellow Cab. Was there a time in

the not too distant past where you drove

three people who were connected with a media

organization to the airport?

A. Yes, sir.

Q. Did you come to know which media

organization these people were connected

with?

A. I think it was Fox Network, and I

think it was getting a lie detector test or

something is what they was talking about.

Q. They were taking a lie -- giving a

lie detector test to whom?

A. To Loyd Jowers.

Q. These media people were giving a lie

detector test to Loyd Jowers?

A. Right.

Q. Could it be that those people

represented the ABC Network?

A. It may have been. I just know they

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was some kind of a TV crew, and the guy that

gave that test was supposed to be an FBI

agent. And then I found out he was not. He

was an ex-FBI agent or something is what they

told me anyway.

Q. These were people you drove -- where

did you pick them up in Memphis?

A. From the Hotel Peabody.

Q. You picked them up at the Hotel

Peabody, and they instructed you to drive to

the airport?

A. To the airport, right.

Q. And how were they seated in your cab?

A. Well, the one that actually gave the

lie detector test was sitting in the front

seat with me, and there was a lady behind him

and there was a little short man behind me.

Q. Do you remember when that was,

Mr. Adams, approximately?

A. No, not right off hand. I hadn't

really checked.

Q. And did you overhear conversation in

your cab in front of you, beside you, behind

you as you drove to the airport?

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A. Yes, sir.

Q. And would you tell the Court and the

jury what was the nature of that

conversation?

A. Well, the man in the front seat asked

the man in the back seat about what do you

think about this Jowers fellow, and I

didn't -- I had the window rolled down and

couldn't exactly hear what he said, but when

I heard Jowers, which I know, I rolled the

window up a little bit.

The man in the front seat said I

couldn't get the man to waver at all. He

said I actually tried to get him to tell a

lie where I could get a feel for him. He

said normally I can get a feel for people

like him. And then the man in the back seat

said, well, maybe he was on some kind of

drugs, and he said, well, yeah, but what are

you going to do, give him a urine test right

there in front of everybody, you know.

And then the lady next to him said

it was hard to believe that he could remember

all these little details over 30 years ago.

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And then the man next to her said, yeah,

unless he had something to do with it, and

then the man asked me -- I mean I asked him,

I said you all talking about Loyd Jowers, and

he said, yeah, do you know him? I said,

yeah, I know him. He said you think he's

capable of doing something like this, and I

said yeah. And then he said he probably done

it himself, didn't he? And I said probably.

Q. But coming back to the initial

exchange that you overheard, really against

his own interest, this examiner was saying I

couldn't get him, meaning Mr. Jowers, to

waver at all. To lie at all?

A. Well, he didn't lie. He said waver.

Q. Waver.

A. You know, that's the words that he

said. He said waver at all. He said I

couldn't get the man to waver at all. He

said I actually tried to get him to tell a

lie where I could get a feel for him. He

said normally I can get a feel for people

like this.

Q. So he tried to get Mr. Jowers to tell

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a lie, but he couldn't get him to waver at

all?

A. That's what it sounds like.

Q. That's what he said to you?

A. Yes.

Q. Well, not to you, but that's what he

said in front of you?

A. Yeah, that's what he said.

Q. Did you come to know what were the

publicly made results of that lie detector

test?

A. Well, as soon as I heard this, I

told, you know, another driver that was kind

of involved in this case, James Millner, that

they gave Loyd Jowers a lie detector test.

And I said whatever he said, that he passed

the test. That's what I told him because

that's the way they talked in the cab.

Q. So you were under the impression that

Mr. Jowers passed the test, right?

A. Right.

Q. What did the media actually report

about Mr. Jowers in that test, do you recall?

A. Well, after I found out it was going

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to be on TV, I watched -- I got the last part

of it where he was telling him about the

gun -- the man handed him the gun and all

that. And then the man went in the room and

he come back out and asked Mr. Jowers did he

want to know the results of his test. And he

says yeah, and he said, well, you lied about

everything.

And he said are you in this for some

kind of money deal or something like that,

and he said, no, I ain't making a dime out of

this. And I heard somebody in the background

say this interview is over with, and they

walked out.

Q. So a national television program

aired this program focusing on the lie

detector test and announced to the world that

Mr. Jowers lied.

A. Right.

Q. But in your cab --

A. It sounded like he was telling the

truth.

MR. PEPPER: Thank you,

Mr. Adams. No further questions.

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CROSS-EXAMINATION

BY MR. GARRISON:

Q. Mr. Adams, you've known Mr. Jowers

some time I gather, haven't you?

A. Quite a few years. It just happened

to be that I knew he was in the cab business,

and I've seen him here and there, and I've

talked to him occasionally. But it seemed

like when he was at one cab company, I was at

the other cab company, but we have -- I've

worked at the cab company that he was working

at at one time which was Veterans Cab

Company.

Q. He never talked to you about anything

about the assassination of Dr. King, anything

he had to do with it, has he?

A. No, sir.

Q. And as far as the questions that were

asked you, they didn't really tell you what

questions they asked him, did they?

A. No.

Q. None of the people in the cab company

told you what questions they asked him, did

they?

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A. No, they didn't.

Q. But you saw the TV where they said

that he failed the polygraph test, a lie

detector test; is that right?

A. Yeah, I seen that on TV.

Q. That what the examiner said, that he

failed the test.

A. That's what the examiner said.

Q. Thank you.

A. That was the same guy that was in my

cab.

MR. GARRISON: Thank you, sir.

MR. PEPPER: Nothing further,

Your Honor.

THE COURT: All right, sir. You

may stand down. You can remain in the

courtroom or you are permitted to leave.

(Witness excused.)

MR. PEPPER: May we approach,

Your Honor?

THE COURT: Yes.

(Dr. Pepper and Mr. Garrison

confer with the Judge at the bench without

the court reporter present.)

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MR. PEPPER: Your Honor,

plaintiffs call Ms. Yolanda King to the

stand.

THE COURT: All right, sir.

YOLANDA KING,

having been first duly sworn, was examined

and testified as follows:

DIRECT EXAMINATION

BY MR. PEPPER:

Q. Good afternoon, Ms. King.

A. Good afternoon.

Q. Airport difficulties notwithstanding,

thank you for joining us here this afternoon.

A. Thank you.

Q. Would you state your full name and

city of residence for the record?

A. Yolanda King. I live currently in

Los Angeles.

Q. What is your current work activity or

profession?

A. I work as an actress and producer.

Q. And you are the daughter of Martin

Luther King, Junior?

A. Yes, I am.

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Q. Would you tell the court and jury

your reason, as you see it, for this lawsuit

being brought? Since each of the plaintiffs

have a separate interest, in addition to a

joint interest obviously, it's important that

we hear why you think this action is being

brought.

A. Well, I think even as a young

person -- younger person, I always felt that

there was more information, there was much

more to the facts than what had been reported

and what had been concluded. And while I

personally emotionally could not pursue it

myself, I thought it was very important

always that the full truth be known, that the

actual truth be known. And so it has been

actually for me personally a real sense of

peace that this is happening, the fact that

more and more of what actually happened will

be revealed to the American people.

Q. Thank you. Now, does the factor of

money or money judgment against the defendant

in this case enter into your interest in it?

A. No, not at all. There really -- that

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is not a consideration, was never a

consideration. It has always been for me,

for the family a question of allowing the

truth to go forth.

Q. So the family is not interested nor

has it requested any large amount of damages

from the defendant?

A. Absolutely not.

Q. Have you participated in discussions

with other members of the family about the

action, and is it your sense that this is

their feeling as well?

A. Very much, very much. We, I think,

all came to an understanding and a unity of

understanding at different times and

different points in our lives. I think

perhaps I was one of the first, but I'm the

first born so -- and older and closer. But I

think we have all come to a very unified

decision in terms of the importance of what

is happening here and also the reason why it

is so important and so significant.

Q. How old were you, Ms. King, when your

father was taken from you?

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A. I was twelve.

Q. And you were the eldest of the

children?

A. Exactly, uh-huh.

Q. And do you remember that loss and

that tragedy even today?

A. Oh, very much, very much. While it

took me a long time to really mourn the

loss -- for a long time I pretended that he

was just away, and because he was away a lot,

it was easy to do that. I was an adult when

I really mourned my father and really the

significance and the impact of the loss. I

allowed that to come forth, but it is -- I

guess you never get to the point where you

ever really get over it completely.

Q. Do you think this process, as taxing

as it may be for the members of the family,

is helping in that whole reconciliation?

A. Yes, and in the healing -- in the

healing. I know for myself personally I am

able to look at it in a very different way

than I was previously and to really -- really

find the sense of, as I said earlier, peace

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about how things -- what happened and why.

And while needless to say we don't know all

of the facts, more and more has come to

light, and I just think it's extremely not

only personally important, but important for

the country as well.

Q. Yes. The defendant in this case of

course is Mr. Lloyd Jowers. Should he be

found libel, which is what happens in a civil

proceeding as His Honor has explained to the

jury at the outset -- should he be found

libel and culpable with being a participant

with other unknown co-conspirators, how would

you feel about Mr. Jowers? Would you have

enmity toward him? What would your feeling

be for the defendant should that verdict come

down?

A. I think a large part of the reason

because we grew up with a very strong and I

think a very honest faith and that faith and

belief has taught us and we've seen in action

the power of forgiveness and the importance

of it, I would not -- I do not feel any kind

of negative feelings towards Mr. Jowers. I

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think that he was part of what was

unfortunately a result of the climate that

was created and encouraged during that time.

MR. PEPPER: Ms. King, thank you

very much.

THE WITNESS: You're welcome.

MR. PEPPER: No further

questions.

MR. GARRISON: I don't have any

questions of Ms. King. Thank you.

THE COURT: Very well, ma'am.

You may step down.

(Witness excused.)

THE COURT: How long did you say

your deposition is?

MR. PEPPER: It's about 40

minutes.

THE COURT: Forty minutes.

MR. PEPPER: We're prepared to

move it over, Your Honor.

THE COURT: Let's take a vote.

Well, we've already got some no's. I can

understand. It's getting rather late, and it

gets dark pretty early now. So let's stop it

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here, and we'll resume tomorrow at 10:00.

(Jury out at 4:30 p.m.)

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