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          1                   UNITED STATES DISTRICT COURT
 
          2            FOR THE WESTERN DISTRICT OF NORTH CAROLINA
 
          3                        CHARLOTTE DIVISION
 
          4
               UNITED STATES OF AMERICA,    )
          5                                 )
                                            )
          6            vs.                  )  File No. 3:97CR23-P
                                            )
          7    AQUILIA MARCIVICCI BARNETTE, )
                                            )
          8            Defendant.           )
                                            )
          9
 
         10
 
         11                 Transcript of proceedings before the Honorable
 
         12    ROBERT D. POTTER, Senior United States District Court Judge,
 
         13    before Scott A. Huseby, Official Court Reporter and Notary
 
         14    Public, on the 22nd day of January, 1998.
 
         15    APPEARANCES:
 
         16    For the United States:
 
         17       ROBERT J. CONRAD, JR.
                  THOMAS G. WALKER
         18       Assistant United States Attorneys
                  227 West Trade Street, Suite 1700
         19       Charlotte, North Carolina  28204
 
         20    On Behalf of the Defendant:
 
         21       GEORGE V. LAUGHRUN, Esq.
                  Suite 602
         22       301 South McDowell Street
                  Charlotte, North Carolina  28204
         23
 
         24
 
         25
 
 
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          1    APPEARANCES: (Continued)
                  PAUL J. WILLIAMS, Esq.
          2       Suite 801
                  301 South McDowell Street
          3       Charlotte, North Carolina  28204
 
          4
 
          5                              ---
 
          6
 
          7            THE COURT:  Good morning, everyone.
 
          8            MR. CONRAD:  Good morning, Judge.
 
          9            MR. LAUGHRUN:  Good morning, Your Honor.
 
         10            THE COURT:  I understand Mr. Laughrun says that
 
         11    Mr. Conrad wants to put something on the record.  Is that right,
 
         12    Mr. Conrad?
 
         13            MR. CONRAD:  Not that I know of.
 
         14            MR. LAUGHRUN:  Well, Judge, yesterday afternoon we
 
         15    had --
 
         16            THE COURT:  Maybe you wanted him to put it on the
 
         17    record.
 
         18            MR. LAUGHRUN:  Well, no.  Yesterday afternoon, he and I
 
         19    talked about the Jencks request we made about 4:00 o'clock,
 
         20    4:15, whenever we recessed.  We talked about whether or not
 
         21    there would be any witnesses who had Jencks material.  He
 
         22    informed me and I take him at his word as I always have that
 
         23    there is no witness for the government going to testify that
 
         24    testified before the Grand Jury, and if that's the case our
 
         25    Jencks request is a moot issue, if Your Honor please.
 
 
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          1            MR. CONRAD:  That's what I told him.
 
          2            THE COURT:  Do you want the put on the record what you
 
          3    said?
 
          4            MR. CONRAD:  That's what I told him.
 
          5            THE COURT:  Okay, thank you.
 
          6            MR. LAUGHRUN:  Judge, also, there are some folks in the
 
          7    courtroom, we don't know if they're witnesses or not, and I --
 
          8    other than the victim impact witnesses, Your Honor already has
 
          9    ruled on over our objection.
 
         10            THE COURT:  Any witnesses back there?  Shouldn't be.
 
         11            (No response.)
 
         12            MR. LAUGHRUN:  I mean, we just don't know who they are
 
         13    and we would just make that request.
 
         14            THE COURT:  Thank you, sir.  Call the jury.
 
         15            (The jury returned to the courtroom.)
 
         16            THE COURT:  Good morning, ladies and gentlemen, hope you
 
         17    had a pleasant evening.  I'm going to have to ask you each
 
         18    morning whether or not any of you have seen, heard or read
 
         19    anything about this case.
 
         20            (No response.)
 
         21            THE COURT:  Anybody discuss it with you?
 
         22            (Jurors shake heads.)
 
         23            THE COURT:  All right, thank you very much.  I
 
         24    understand from the shaking of the heads that nobody has seen,
 
         25    heard or read anything about it, nor has anyone discussed it
 
 
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          1    with you, is that correct?
 
          2            (Jurors nod heads.)
 
          3            THE COURT:  Thank you very much.  Call your next
 
          4    witness.
 
          5            MR. CONRAD:  The United States would call Melinda
 
          6    Burden.
 
          7            MR. WILLIAMS:  What is the name of the witness?
 
          8            MR. CONRAD:  Burden.
 
          9                             MELINDA BURDEN,
 
         10    being first duly sworn, was examined and testified as follows:
 
         11                           DIRECT EXAMINATION
 
         12            BY MR. CONRAD:
 
         13       Q.   Would you please state your name for the jury?
 
         14       A.   Melinda Burden.
 
         15       Q.   Ms. Burden, how old are you?
 
         16       A.   17.
 
         17       Q.   In April of '96, how old were you?
 
         18       A.   16.
 
         19       Q.   Where do you live?
 
         20       A.   Roanoke.
 
         21       Q.   Now, in April of 1996, what was your street address?
 
         22       A.   I can't remember.
 
         23       Q.   Okay.  Let me approach and hand to you what's been
 
         24    introduced into evidence as Government's Exhibits 7F, G, H and
 
         25    I, and ask if you recognize this area of Roanoke?
 
 
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          1       A.   Yes, I do.
 
          2       Q.   Okay, and what do you recognize it as?
 
          3       A.   That was my house (indicating) right there.
 
          4       Q.   All right.  And do you know Robin Williams?
 
          5       A.   Oh, no, I didn't know her personally.
 
          6       Q.   Did you know where she lived?
 
          7       A.   Uh-huh, right here.
 
          8       Q.   Okay.  So your house is right here (indicating)?
 
          9       A.   Uh-huh.
 
         10       Q.   And Robin Williams' house is on the corner that you just
 
         11    pointed out?
 
         12       A.   Uh-huh.
 
         13       Q.   Is there -- does your house include this property in
 
         14    here (indicating)?
 
         15       A.   All the way to back here it does (indicating).
 
         16       Q.   And is there a path that goes through that area?
 
         17       A.   Yes, there is a way you can come over here in the yard
 
         18    and look all the way down and see everything down here.
 
         19       Q.   If you go down that path, can you see Robin Williams'
 
         20    apartment from your property?
 
         21       A.   Uh-huh.
 
         22       Q.   In April of 1996, did anything unusual happen?
 
         23       A.   Yes.
 
         24       Q.   In the wee hours of the morning?
 
         25       A.   Uh-huh.
 
 
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          1       Q.   Go ahead and tell the jury what happened.
 
          2       A.   I was sleeping and I heard, I think it was four
 
          3    gunshots.
 
          4       Q.   Uh-huh?
 
          5       A.   And I woke up and I went outside, and I heard this woman
 
          6    screaming and banging on the people's doors screaming, help me,
 
          7    help me, he is going to kill me.  And I heard glass breaking,
 
          8    and I seen a car come up my road with loud music on, and the
 
          9    person that was in it went down a dead end street, came back
 
         10    right by my house, by me and my mother.  And he had his arm up,
 
         11    looked like he was adjusting the rear view mirror, and I seen
 
         12    the fire of a cigarette in the passenger seat, and that's really
 
         13    all I seen.
 
         14            MR. CONRAD:  That's all I have, Judge.
 
         15            THE COURT:  Cross?
 
         16                            CROSS-EXAMINATION
 
         17            BY MR. LAUGHRUN:
 
         18       Q.   Ms. Burden, did you give a statement to the police,
 
         19    ma'am?
 
         20       A.   My mother did.
 
         21       Q.   No, did you give one, ma'am?
 
         22       A.   No, sir.
 
         23       Q.   Give a statement to any FBI agents?
 
         24       A.   Yes.
 
         25       Q.   Who did you talk to, ma'am?
 
 
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          1       A.   I think it was Mr. Conrad.
 
          2       Q.   Mr. Conrad being the prosecutor here?
 
          3       A.   Yes.
 
          4       Q.   Did you talk to anybody besides Mr. Conrad or Mr. Walker
 
          5    seated at that table?
 
          6       A.   Yeah, I talked to a man that came to my house.
 
          7       Q.   Did he write down what you said?
 
          8       A.   No.
 
          9       Q.   Did he record it on tape or any way at all?
 
         10       A.   No.
 
         11       Q.   Is that someone from the Roanoke police department?
 
         12       A.   Yes, I think.
 
         13       Q.   Now, you folks had some dogs on your property, did you
 
         14    not?
 
         15       A.   Right.
 
         16       Q.   When you lived there?
 
         17       A.   Yes, we had one.
 
         18       Q.   And did it sleep outside?
 
         19       A.   Yes.
 
         20       Q.   Was it barking that night?
 
         21       A.   I'm not sure.
 
         22       Q.   And you can't identify anybody in the car, can you?
 
         23       A.   No.
 
         24       Q.   Can you give us a description of the car?
 
         25       A.   It was like a little sports car.  It had primer spots on
 
 
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          1    it.
 
          2       Q.   Okay.  Have you ever been shown a picture of that car at
 
          3    all?
 
          4       A.   No.
 
          5            MR. LAUGHRUN:  Thank you, ma'am.  Thank you, Judge
 
          6    Potter.
 
          7            THE COURT:  Redirect?
 
          8            MR. CONRAD:  No, sir.
 
          9            THE COURT:  Thank you, ma'am, appreciating you coming,
 
         10    thank you.  Call your next witness.
 
         11            MR. CONRAD:  The United States would call Maude
 
         12    Hubbard.
 
         13                            MAUDE G. HUBBARD,
 
         14    being first duly sworn, was examined and testified as follows:
 
         15                           DIRECT EXAMINATION
 
         16            BY MR. CONRAD:
 
         17       Q.   Ms. Hubbard, can you state your name for the jury?
 
         18       A.   My name is Maude G. Hubbard, and the G is for Gail.
 
         19       Q.   Do they also call you Granny?
 
         20       A.   Right, right.
 
         21       Q.   Where do you live, Ms. Hubbard?
 
         22       A.   I live at 1618 Keswick Avenue, Northeast, that's -- I
 
         23    moved downstairs.  I were staying at 1614.  They moved me down
 
         24    up underneath there.
 
         25       Q.   And that's in Roanoke?
 
 
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          1       A.   Right, Roanoke, Virginia.
 
          2       Q.   And 1614, would that be the apartment next to --
 
          3       A.   Next to where Robin, yes, sir.
 
          4       Q.   Next to 1616?
 
          5       A.   Right, right.
 
          6       Q.   And in April of last year, or I'm sorry, April of 1996,
 
          7    were you living in 1614, next door to --
 
          8       A.   Yes, I were.
 
          9       Q.   And then sometime after that, you moved down behind in
 
         10    the back of the apartment?
 
         11       A.   Right, right.
 
         12       Q.   Okay.  Do you know Bertha Williams?
 
         13       A.   Yes, I do.
 
         14       Q.   How do you know Ms. Williams?
 
         15       A.   We all go to church, we are in the same church together,
 
         16    and I been knowing her for a number of years.  We worked
 
         17    together.
 
         18       Q.   Do you see her in the courtroom today?
 
         19       A.   Bertha Williams?
 
         20       Q.   Yes, ma'am.
 
         21       A.   Yes, I do.
 
         22       Q.   Do you know Robin Williams?
 
         23       A.   Yes, I do.
 
         24       Q.   How do you know Robin?
 
         25       A.   I knew her from a young girl when she was in school.  I
 
 
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          1    been knowing her practically all of my life.
 
          2       Q.   And at some time, did Robin move next door to you?
 
          3       A.   Yes, she did.
 
          4       Q.   Okay.  And at some time, did a boyfriend ever move in
 
          5    with her?
 
          6       A.   Yes.
 
          7       Q.   Do you remember the events of the night of the fire
 
          8    bombing?
 
          9       A.   Yes, I do, but I had gone to sleep.  See, I'm a
 
         10    diabetic, and I had went to sleep, and they came there and woke
 
         11    me up and said, Granny, get up, get up, get up.
 
         12       Q.   And who did that?
 
         13       A.   That was Doris Coleman, the lady up the hill from me.
 
         14       Q.   And after Doris Coleman -- how did she wake you up?
 
         15       A.   She just kept hollering, Granny, Granny, Granny, Granny
 
         16    and knocking at the door.  And Mr. Grub stayed down up under me,
 
         17    I'm staying in his apartment now, and he came up there and his
 
         18    little boy and said, Come on, get on out, Granny, get on out.
 
         19    And I seen all of this out there, I just didn't know what was
 
         20    going on.
 
         21       Q.   Okay.  And after Ms. Coleman and Mr. Grub got you up,
 
         22    what happened after that?
 
         23       A.   Well, I just like everybody else, I put my coat and
 
         24    stood there and seen the fire trucks and everything.  And at
 
         25    that time, Ms. Coleman come down, well, see, Robin, I heard
 
 
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          1    someone hollering.  But you know when you are in the apartment
 
          2    at my age, you know, I didn't catch her voice until she went up
 
          3    and then she came back, and then she was hollering Granny,
 
          4    Granny, help me, help me, Granny, this didn't have to happen to
 
          5    me.  And they brought her in there and they had this cloth on
 
          6    her arm, and she went to pull on it and all the flesh and
 
          7    everything fell.  I said, oh, my God.  She said, call my mama,
 
          8    when I tried to -- I didn't have a phone, my wires had been cut.
 
          9       Q.   So as best as you can remember, what did Robin tell you
 
         10    when she came with the towel around her arm, what did she say to
 
         11    you?
 
         12       A.   She just said, Granny, look here, look, Granny, said, he
 
         13    tried to kill me, tried to kill me, said, Granny, I don't
 
         14    deserve this, Granny, I don't deserve this.  And I told her, she
 
         15    said, call my mama.  But I went there to try to call her, but
 
         16    there was no phone, the phone was dead.
 
         17       Q.   Did you pick up your phone?
 
         18       A.   Yeah, I picked it up and it was dead, and I said,
 
         19    Robin --
 
         20       Q.   There was no dial tone?
 
         21       A.   No dial tone whatsoever.
 
         22       Q.   Did you later learn what happened to your phone?
 
         23       A.   Yes.
 
         24       Q.   Tell the jury about that.
 
         25       A.   I learned that Mark had cut my line and hers.
 
 
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          1       Q.   And how did you learn that?
 
          2       A.   Huh?
 
          3       Q.   How did you learn that?
 
          4       A.   Well, that's what Mr. Grub said, it's the only way,
 
          5    because everybody else had telephone service but me and Robin.
 
          6       Q.   Did he show you anything, Mr. Grub, did Mr. Grub show
 
          7    you anything the next day?
 
          8       A.   Yeah, next day he went out there and just, you know, put
 
          9    it back for me.
 
         10       Q.   Did you see the phone lines?
 
         11       A.   Yeah, it was -- before he cut it, he showed me, uh-huh.
 
         12       Q.   All right.  Now, with Robin living next door to you, did
 
         13    you -- did you have occasion to see her coming and going?
 
         14       A.   Yeah, I seen her coming and going to work.
 
         15       Q.   Did you ever see her boyfriend Mark Barnette come?
 
         16       A.   Yes, all the time, because he drove the car most of the
 
         17    time.  He'd take her to work and go pick her up from work.
 
         18       Q.   And you would see Mr. Barnette doing that?
 
         19       A.   Yeah, I seen him, uh-huh.
 
         20       Q.   Would Robin drive the car or would Mr. Barnette?
 
         21       A.   Mr. Barnette.  He did most of the driving.
 
         22       Q.   And whose car was it?
 
         23       A.   It was Robin's.
 
         24       Q.   Okay.  Now, you had indicated that your -- you are a
 
         25    family friend, is that accurate, you're a friend of the Williams
 
 
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          1    family?
 
          2       A.   Right, right.
 
          3       Q.   Long time?
 
          4       A.   Long time.
 
          5       Q.   After Robin moved in next door to you, did she ever come
 
          6    over and talk with you?
 
          7       A.   Me and her, we just had a little, small stoop.  We'd sit
 
          8    there and talk.  She confirmed different things with me, because
 
          9    she'd always, you know, asking for advice and I -- you know, I
 
         10    have children and I know, and I always talked to her, give her
 
         11    as a mother and a grandmother.
 
         12       Q.   Did she ever talk to you about her relationship with
 
         13    Mr. Barnette?
 
         14       A.   Yes, she did.
 
         15       Q.   And what would she tell you?
 
         16            MR. LAUGHRUN:  Objection, Judge.
 
         17            THE WITNESS:  She just said he done got to be so
 
         18    possessive.
 
         19            MR. CONRAD:  Granny, hang on a second.
 
         20            THE COURT:  Wait just a minute, there's an objection.
 
         21    You're objecting to this on what grounds?
 
         22            MR. LAUGHRUN:  Hearsay, Your Honor.
 
         23            THE COURT:  Overruled.
 
         24            BY MR. CONRAD:
 
         25       Q.   Go ahead, Granny, what did Robin tell you about her
 
 
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          1    relationship with the defendant?
 
          2       A.   She said she couldn't get rid of him, she just didn't
 
          3    want to be bothered with him, she wanted him out of there, he
 
          4    was too possessive.
 
          5       Q.   Did she tell you why she wanted to get rid of him?
 
          6       A.   Because he was fighting her and --
 
          7       Q.   Were there ever any incidents before the fire bombing?
 
          8       A.   Yes, it was, yes, it was.
 
          9       Q.   And would you hear that?
 
         10       A.   Did I hear it?  No, she came back out of the house from
 
         11    her apartment over there to tell me -- to call her mother one
 
         12    night.  He had jumped on her.
 
         13       Q.   And how long before the fire bombing did that occur?
 
         14       A.   It wasn't too long, really I just couldn't exactly tell
 
         15    you the date and all that.
 
         16       Q.   On that night when she came over and said he had jumped
 
         17    on her, what was her attitude like?
 
         18       A.   Nothing, she just said, I want my mama, I want my mama,
 
         19    I'm going to call my mama.  And it wasn't but a few minutes
 
         20    before sister Bertha was there.
 
         21       Q.   So you did call Ms. Williams at least on one occasion to
 
         22    tell her about the fire bombing?
 
         23       A.   Yes, I called her, yeah, I called her.
 
         24       Q.   And then she came over?
 
         25       A.   Yes.
 
 
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          1            MR. CONRAD:  That's all I have, Your Honor.
 
          2            THE COURT:  Cross?
 
          3                            CROSS-EXAMINATION
 
          4            BY MR. WILLIAMS:
 
          5       Q.   When you first, Ms. Hubbard, knew that Robin and Mark
 
          6    were dating, at the beginning of that relationship, she was very
 
          7    happy and in love with Mark, wasn't she?
 
          8       A.   Seemed like it to me, she did.
 
          9            MR. WILLIAMS:  Thank you.
 
         10            THE COURT:  Redirect?
 
         11            MR. CONRAD:  No, sir.
 
         12            THE COURT:  Thank you, ma'am, you may step down,
 
         13    appreciating you coming.  Call your next witness.
 
         14            MR. CONRAD:  The United States would call Ray Williams.
 
         15                              RAY WILLIAMS,
 
         16    being first duly sworn, was examined and testified as follows:
 
         17                           DIRECT EXAMINATION
 
         18            BY MR. CONRAD:
 
         19       Q.   Sir, would you state your name for the jury?
 
         20       A.   Ray Williams.
 
         21       Q.   Mr. Williams, are you related to Bertha Williams?
 
         22       A.   Brother, yes, sir.
 
         23       Q.   She is your sister?
 
         24       A.   Yes, sir.
 
         25       Q.   Do you see Bertha in the courtroom today?
 
 
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          1       A.   Today?
 
          2       Q.   Yes.
 
          3       A.   Yes, I see her back there.
 
          4       Q.   So, Robin Williams would be your niece?
 
          5       A.   That's right.
 
          6       Q.   Do you remember an incident -- I'm sorry, Mr. Williams,
 
          7    where do you live?
 
          8       A.   I live at 703 Hunt Avenue, Roanoke, apartment 27.
 
          9       Q.   And back in April of 1996, where did you live?
 
         10       A.   911 Loudon.
 
         11       Q.   And is that your sister Bertha's house at 911 Loudon
 
         12    Avenue in Roanoke?
 
         13       A.   Yes, sir.
 
         14       Q.   Do you remember a time in April when -- did you know
 
         15    where Robin lived back then?
 
         16       A.   Yes, I did.
 
         17       Q.   Did you recall a time when her apartment was fire
 
         18    bombed?
 
         19       A.   Yes, sir.
 
         20       Q.   Where did Robin go after her apartment was fire bombed?
 
         21       A.   She went to the hospital.
 
         22       Q.   And how long was she at the hospital, best you can
 
         23    remember?
 
         24       A.   I don't remember all that, but she was in there quite a
 
         25    while.
 
 
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          1       Q.   Okay.  And during the time that she was at the hospital,
 
          2    do you know if that hospital was in Charlottesville, Virginia?
 
          3       A.   Charlottesville.
 
          4       Q.   And was your sister Bertha in Charlottesville at that
 
          5    time with Robin?
 
          6       A.   Yes, sir, all the time.
 
          7       Q.   And were you living -- strike that.
 
          8            Was your nephew Kenneth with his mother in
 
          9    Charlottesville?
 
         10       A.   Yes, he was.
 
         11       Q.   So were you living by yourself at 911 Loudon during that
 
         12    time?
 
         13       A.   At that time, yes.
 
         14       Q.   And during that time when Robin was at the hospital in
 
         15    Charlottesville, did you receive a phone call?
 
         16       A.   I sure did.
 
         17       Q.   All right, and go ahead and tell the jury about that
 
         18    phone call.
 
         19       A.   Well, the -- the fellow called and wanted to say he was
 
         20    concerned about Robin, wanted to know how she was.
 
         21            MR. LAUGHRUN:  Objection to hearsay.
 
         22            THE COURT:  Wait a minute.  Objection overruled, go
 
         23    ahead.
 
         24            THE WITNESS:  And wanted to know where she was at, and I
 
         25    told him, you know where she is at.
 
 
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          1            BY MR. CONRAD:
 
          2       Q.   Let me stop you right there Mr. Williams and ask you a
 
          3    couple of questions.  When the fellow called and asked about
 
          4    Robin, did you recognize the voice?
 
          5       A.   I sure did.
 
          6       Q.   How did you recognize the voice?
 
          7       A.   Well, I knew who he was, because I been seeing him the
 
          8    whole time he was with Robin.
 
          9       Q.   And whose voice was it that you heard on the phone?
 
         10       A.   Well, it was Mark.
 
         11       Q.   Do you see the person you've called Mark in the
 
         12    courtroom today?
 
         13       A.   Yes, right there.
 
         14       Q.   Would you point him out to the jury and tell the jury
 
         15    what he is wearing?
 
         16       A.   There he is right there.
 
         17       Q.   At the table next to me?
 
         18       A.   Next to you.
 
         19       Q.   Sitting in the middle between two gentlemen?
 
         20       A.   Yes, sir.
 
         21       Q.   Now, prior to getting that phone call, how many times
 
         22    had you seen or heard Mark's voice?
 
         23       A.   Oh, every time he come up to the house or come around,
 
         24    you know, I knew who it was.
 
         25       Q.   Is there any doubt in your mind that's who you talked to
 
 
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          1    on that phone?
 
          2       A.   No, sir.
 
          3       Q.   Okay.  Now, as best you remember, tell the jury exactly
 
          4    how the conversation went.
 
          5       A.   From what I remember, he called and asked me how was
 
          6    Robin.
 
          7       Q.   And what did you say?
 
          8       A.   I just remember, but he said, what did he say, he was
 
          9    concerned about Robin, where was she at, and I told him, you
 
         10    know where she is at, just like that.  And we just had a few
 
         11    more words or something like that, you know.
 
         12       Q.   Did you ask him why he did it?
 
         13       A.   I sure did.  I said, Mark, why would you do something to
 
         14    Robin like that, and he told me, sir, Ray, I didn't do it but I
 
         15    know who done it, just like that.  And I told him he is a
 
         16    goddamn liar, just to use my expression, and hung up in his
 
         17    face.
 
         18       Q.   And after you hung up with him, what did you do?
 
         19       A.   I just remember I think I called somebody, I don't know
 
         20    who I called.
 
         21       Q.   Do you remember calling Kenny?
 
         22       A.   I talked to Kenny on the phone.
 
         23       Q.   After you hung up, did you make any attempt to figure
 
         24    out what number he had called you from?
 
         25       A.   Well, he told me, Kenny told me to --
 
 
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          1            MR. LAUGHRUN:  Objection.
 
          2            THE WITNESS:  -- look on the --
 
          3            MR. LAUGHRUN:  Objection.
 
          4            THE COURT:  Overruled.
 
          5            MR. CONRAD:  Go ahead, Ray.
 
          6            THE WITNESS:  To look on the box and get the number, but
 
          7    I really don't remember too much about that.
 
          8            BY MR. CONRAD:
 
          9       Q.   Well, did you -- let me ask you this:  Did you look on
 
         10    the box and get the number?
 
         11       A.   Yeah, I did, I did.  I wrote the number down.
 
         12       Q.   You wrote the number down.  Did you ever tell Kenny the
 
         13    number?
 
         14       A.   Yes, I did.
 
         15            MR. CONRAD:  That's all I have.
 
         16            THE COURT:  Cross?
 
         17            BY MR. WILLIAMS:
 
         18       Q.   Mr. Williams, just very briefly.  When you first met
 
         19    Mark and knew that they were -- he had met and began a
 
         20    relationship, at the beginning of that relationship you knew
 
         21    that Robin and he were very much in love?
 
         22       A.   I don't know nothing about all that being very much in
 
         23    love, it was just a little old fling, you know, that's all I
 
         24    thought it was, a little old fling.
 
         25       Q.   When Mark moved into the apartment with Robin, didn't
 
 
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          1    you help Mark move in?
 
          2       A.   Did I help?  I was there.  I didn't help, I couldn't do
 
          3    nothing.
 
          4            MR. WILLIAMS:  Thank you, sir.
 
          5            THE COURT:  No redirect, thank you very much.
 
          6            THE WITNESS:  Yes, sir.
 
          7            THE COURT:  Call your next witness.
 
          8            MR. CONRAD:  The United States would call Kenneth
 
          9    Williams.
 
         10                            KENNETH WILLIAMS,
 
         11    being first duly sworn, was examined and testified as follows:
 
         12                           DIRECT EXAMINATION
 
         13            BY MR. CONRAD:
 
         14       Q.   Would you tell the jury your name, please?
 
         15       A.   Kenneth Williams.
 
         16       Q.   Kenneth, you are going to have to pull that microphone
 
         17    closer to you.
 
         18       A.   Kenneth Williams.
 
         19       Q.   And Kenneth, do you live in Roanoke, Virginia?
 
         20       A.   Yes, sir, that's correct.
 
         21       Q.   Are you related to Bertha Williams?
 
         22       A.   Yes, sir.
 
         23       Q.   How?
 
         24       A.   That's my mother.
 
         25       Q.   And so Robin Williams would be your sister?
 
 
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          1       A.   Yes, sir.
 
          2       Q.   Now, you've been in the courtroom during this testimony,
 
          3    have you not?
 
          4       A.   Yes, sir.
 
          5       Q.   Did you hear your Uncle Ray just testify?
 
          6       A.   Yes, sir.
 
          7       Q.   Did there come a time when you talked to him from
 
          8    Charlottesville, Virginia?
 
          9       A.   Yes, sir.
 
         10       Q.   And what did you talk about?
 
         11       A.   Well, I was down there and I called up there because he
 
         12    was staying at my mother's house to see if he was all right.
 
         13    And we talked, and then he told me that Mark had called there
 
         14    and he told me what he had said, where she was at.  And then
 
         15    I -- and then I hung up, and then I went back in the room
 
         16    because I called from a pay phone.  And I told my mother to come
 
         17    outside or something, out of the room because I didn't want my
 
         18    sister to hear, and I told her that Uncle Ray said that he had
 
         19    called.  And she said, Kenny, call him back and tell them to
 
         20    push the I.D. and get the number, so I did.  Then afterwards --
 
         21       Q.   Just take your time, Kenny.
 
         22       A.   Huh?
 
         23       Q.   Just take your time.
 
         24       A.   Okay.  And then afterwards, I called the operator to see
 
         25    what area code, what city, and she told me it was North
 
 
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          1    Carolina, so I said okay.  So the next day --
 
          2       Q.   Did there come a time -- did your Uncle Ray give
 
          3    you -- did he -- do you know whether or not he pushed the I.D.
 
          4    button to get that number?
 
          5       A.   Well, I didn't actually see him do that.
 
          6       Q.   Right, but did there come a time when he gave you a
 
          7    number?
 
          8       A.   Yes, sir, that's correct.  That's when I called him back
 
          9    because my mother told me to call him back, and I asked, and I
 
         10    said, Uncle Ray, mama said push the caller I.D. to see if there
 
         11    is a number, and he did and he gave me the number.
 
         12       Q.   Did there come a time when you took that number and
 
         13    called the Roanoke Police Department?
 
         14       A.   Yes, sir, that's correct.
 
         15       Q.   And did you give that number to them?
 
         16       A.   Yes, sir.  I called the next day, because it was at
 
         17    night.  The next day I called down to the office of the
 
         18    detective that was in charge.  I didn't talk to Mr. Kahl or
 
         19    nothing.  I talked to somebody and I told them what had
 
         20    happened, told them who I was, and gave them the phone number
 
         21    and told them what had happened and that was it.
 
         22            MR. CONRAD:  No further questions.
 
         23            THE COURT:  Cross?
 
         24            MR. WILLIAMS:  No questions, Mr. Williams.
 
         25            THE COURT:  Thank you, sir.  Call your next witness.
 
 
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          1            MR. CONRAD:  The United States would call Sydney
 
          2    Williams.
 
          3                            SYDNEY WILLIAMS,
 
          4    being first duly sworn, was examined and testified as follows:
 
          5                           DIRECT EXAMINATION
 
          6            BY MR. CONRAD:
 
          7       Q.   Would you tell the jury your name, please?
 
          8       A.   Sydney Williams.
 
          9       Q.   Sydney, are you Robin's brother?
 
         10       A.   Yes, I am.
 
         11       Q.   Where do you live, Sydney?
 
         12       A.   I live at 1441 Leon Street, Northwest, Roanoke,
 
         13    Virginia.
 
         14       Q.   And how long have you lived there?
 
         15       A.   About six, five years.
 
         16       Q.   And do you know Mark Barnette?
 
         17       A.   Yes, I do.
 
         18       Q.   Do you see him the courtroom today?
 
         19       A.   Yes, I do.
 
         20       Q.   Could you point him out and describe him to the jury?
 
         21       A.   The gentleman right there in the middle of the two
 
         22    lawyers with the blue suit coat on.
 
         23       Q.   How do you know Mark Barnette?
 
         24       A.   He was dating my sister.  We used to have family outings
 
         25    together and everything and he came around.
 
 
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          1       Q.   How frequently did you see him?
 
          2       A.   Well, I seen him like maybe once a month or maybe a
 
          3    little bit more than that, because I used to work right around
 
          4    the corner from where they were staying at and I used to go on
 
          5    lunch break and go by there to check on her.
 
          6       Q.   Back in April of 1996, where were you working?
 
          7       A.   April of '96?  At the golf course.
 
          8       Q.   And where was that golf course located?
 
          9       A.   It was located up by -- because like then, see, I was
 
         10    actually living across the corner from them, but then I had
 
         11    moved to the golf course, so that was like maybe two miles away
 
         12    from my house on the other side of town.
 
         13       Q.   And what did you do at the golf course?
 
         14       A.   Actually cut the greens and the intermediates.
 
         15       Q.   And from time to time while you were working at the golf
 
         16    course, would you come home for lunch?
 
         17       A.   Yes, I used to go home for lunch every day.
 
         18       Q.   Now, you remember the fire bombing, do you not?
 
         19       A.   Yes, I was called to the fire.
 
         20       Q.   Sometime after the fire bombing, do you recall coming
 
         21    home for lunch from work and finding anything unusual?
 
         22       A.   Yes.  Well, I had my sister's car parked at my house,
 
         23    because my sister was in the hospital and we was running back
 
         24    and forth up the interstate.
 
         25       Q.   Go ahead and speak up if you can.
 
 
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          1       A.   Okay.
 
          2       Q.   What kind of car did your sister have?
 
          3       A.   She had a green Toyota.
 
          4       Q.   Okay.  And where was your sister when her car was parked
 
          5    at your house?
 
          6       A.   She was in the hospital.
 
          7       Q.   And go ahead, you were about to tell the jury what
 
          8    happened on the day that you came home from the golf course when
 
          9    your sister's car was parked at your house.  Go ahead and tell
 
         10    them.
 
         11       A.   Okay.  Well, like when you come to my house, I had a car
 
         12    facing the carport, so I just walked right by the house and I
 
         13    went in and made me a couple of sandwiches.  And when I came out
 
         14    of the house, you know, because when I walked by the house, I
 
         15    didn't really like look at the front of the car, and I went and
 
         16    made a couple sandwiches and I came back out and I seen the
 
         17    cards on her windshield with the windshield wipers holding the
 
         18    cards on the windshield.
 
         19       Q.   What kind of cards were they?
 
         20       A.   They was like old cards that she had wrote to him like
 
         21    when they was together or having a long distance
 
         22    conversation -- I mean, a long distance relationship.
 
         23       Q.   Okay.  And after you found those cards on her
 
         24    windshield, what did you do?
 
         25       A.   I proceeded to be late for work and went straight down
 
 
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          1    to my mom's to check on her because she had came home then.
 
          2       Q.   Who had come home then?
 
          3       A.   My sister Robin, she had came home from the hospital.
 
          4    My mom was at work and I was at work and everything, so I went
 
          5    straight down there and I checked the house and checked on her.
 
          6    And so I got on the phone and I called --
 
          7       Q.   Now, when you went over to your mother's house, was
 
          8    Robin there alone?
 
          9       A.   Yes.  So then I got on the phone and I called over to my
 
         10    Aunt Cary's house and Uncle Ray was there.  So I got in the car
 
         11    and went and picked him up, and I didn't never tell Robin
 
         12    anything, I just went and got my uncle and picked him up from
 
         13    Aunt Cary's and took him to Robin.  But I had told him
 
         14    everything so he could be right there with her.
 
         15       Q.   Why did you do that?
 
         16       A.   Because I didn't know if he was in town or -- he had to
 
         17    have been in town because the cards wasn't there when I left to
 
         18    go to work that morning.
 
         19       Q.   When you say he, who are you referring to?
 
         20       A.   Mark Barnette.
 
         21       Q.   Did you drop Ray off at your mother's house?
 
         22       A.   At my mother's house and went back and walked back
 
         23    around the side of the house to make sure there wasn't anyone
 
         24    around.
 
         25       Q.   All right.  And what did you do after that?
 
 
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          1       A.   Uncle Ray said he was going to take care of everything
 
          2    and be around the house, so then I just proceeded to go back to
 
          3    work.
 
          4       Q.   Let me hand to you what has been marked for
 
          5    identification as Government's Exhibits 50A, 50B, 50C, 50D, 50E,
 
          6    50F and 50G and ask you, Sydney, if you recognize those
 
          7    exhibits?  Go ahead and look at each one.
 
          8       A.   Yes, sir, these are the same cards, because this one
 
          9    right here was right on the top of the stack of cards that was
 
         10    on the windshield of her car.
 
         11       Q.   Go ahead and speak up if you can.
 
         12       A.   Okay.  These are the same cards, because these was the
 
         13    ones that was on the windshield of her car.
 
         14       Q.   And you are referring to 50B as being the card that was
 
         15    on the top?
 
         16       A.   It was right on the top.
 
         17       Q.   All right.  Now, did you look at those cards when you
 
         18    took them off of your windshield?
 
         19       A.   Yes, I did.
 
         20       Q.   Go ahead and take 50B out of the --
 
         21            MR. CONRAD:  Your Honor, I'd move admission of
 
         22    Government's Exhibit 50A through 50G.
 
         23            THE COURT:  They will be admitted.
 
         24            BY MR. CONRAD:
 
         25       Q.   Turning your attention to Government's Exhibit 50B,
 
 
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          1    would you take it out of the plastic and open it up and look at
 
          2    it.  Now, does that have any names on it?
 
          3       A.   Yes.
 
          4       Q.   What names does it have?
 
          5       A.   They got Robin and Mark.
 
          6       Q.   In a heart?
 
          7       A.   And a heart, it's designed in a heart, forever and ever,
 
          8    and it's got Robin to where she signed it right here.
 
          9       Q.   At the bottom of Government's Exhibit 50B?
 
         10       A.   Yes.
 
         11       Q.   Turn your attention to the front of it.  Is there any
 
         12    writing on the front of the card?
 
         13       A.   Yes.
 
         14       Q.   What is the writing?
 
         15       A.   It's got, why did you lie.
 
         16       Q.   Exclamation point?
 
         17       A.   Exclamation point.
 
         18       Q.   Does it look like there's a signature scrawled at the
 
         19    bottom?
 
         20       A.   It's some kind of signature, but I don't really know
 
         21    what it is, I mean, it's like at the bottom.
 
         22       Q.   Now, if you would with each of the exhibits, would you
 
         23    take them out of the plastic, look at them, see if there is any
 
         24    names on the inside?  Turn your attention to Government's
 
         25    Exhibit's 50F.  Is it signed by anybody?
 
 
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          1       A.   Yes, it's signed by Robin.
 
          2       Q.   And turning your attention to the front of that card, is
 
          3    there any writing on the front of the card?
 
          4       A.   Yes, it is.
 
          5       Q.   What does it say?
 
          6       A.   It says, if you loved him so much, why did you even
 
          7    bother with me.  And it got the same like signature thing in the
 
          8    bottom right here.
 
          9       Q.   Does it appear to be initials at the bottom?
 
         10       A.   Yes, same thing as 50B has on the bottom.
 
         11       Q.   Turning your attention to 50G, anything inside, any
 
         12    names mentioned inside?
 
         13       A.   Yes, it's the same right here about Robin, my sister.
 
         14       Q.   And on the front of it, is there any writing on the
 
         15    front of it?
 
         16       A.   Yes.
 
         17       Q.   What does it say?
 
         18       A.   It says, you never really loved me, and it has the same
 
         19    thing at the bottom that the other two exhibits has.
 
         20       Q.   Let me ask you to look at 50E.
 
         21       A.   Yes.
 
         22       Q.   Signed by Robin?
 
         23       A.   Yes, signed by her.  And the front has the, why wasn't I
 
         24    good enough for you, and it got the same signature thing on
 
         25    there.
 
 
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          1       Q.   Okay.  50D?
 
          2       A.   Yes, this one is the same also.
 
          3       Q.   By Robin?
 
          4       A.   By Robin Williams.
 
          5       Q.   And on the front?
 
          6       A.   It got, you lied to me, with the same signature emblem.
 
          7       Q.   50C?
 
          8       A.   This one isn't signed.
 
          9       Q.   It says, loving you more, Poo?
 
         10       A.   Yes, loving you more, Poo, that's what it says.
 
         11       Q.   On the 21st birthday?
 
         12       A.   Yes, that's what it got, right here.
 
         13       Q.   And on the front -- or turning your attention to the
 
         14    back of that card, is there anything written on the back of the
 
         15    card?
 
         16       A.   Yes, it is, sir.
 
         17       Q.   And what does it say?
 
         18       A.   It's got, Robin, you didn't have to lie about Bennie, if
 
         19    you loved him so much, you should have never fucked our
 
         20    lives -- I mean --
 
         21       Q.   Is it faked?
 
         22       A.   -- faked our love, faked your love for me.
 
         23       Q.   And is there a box with more writing?
 
         24       A.   Yes.
 
         25       Q.   What does it say?
 
 
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          1       A.   These are just a sample of your lies.
 
          2       Q.   And finally, 50A?
 
          3       A.   It has Poo on it also.
 
          4       Q.   And on the front, is there writing on the front?
 
          5       A.   Yes, it is.
 
          6       Q.   What is the writing on the front?
 
          7       A.   You let him come between us, with an exclamation point.
 
          8            MR. CONRAD:  Your Honor, may I pass Government's
 
          9    Exhibits 50A through 50G to the jury?
 
         10            THE COURT:  Yes, sir.
 
         11            BY MR. CONRAD:
 
         12       Q.   Sydney, do you know how long after the fire bombing that
 
         13    you came home and found these cards?
 
         14       A.   I would say approximately about, after the fire bombing,
 
         15    because she had just came home, I would say about maybe three
 
         16    weeks.
 
         17       Q.   Three weeks after?
 
         18       A.   After the fire bombing.
 
         19       Q.   How far was your house at that time from 911 Loudon
 
         20    Avenue?
 
         21       A.   Approximately about maybe two and a half to three miles.
 
         22            MR. CONRAD:  That's all I have, Judge.
 
         23            THE COURT:  Cross?
 
         24            MR. WILLIAMS:  I don't have any questions, thank you,
 
         25    sir.
 
 
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          1            MR. WALKER:  Your Honor, the government would call Mark
 
          2    Etters.
 
          3                              MARK ETTERS,
 
          4    being first duly sworn, was examined and testified as follows:
 
          5                           DIRECT EXAMINATION
 
          6            BY MR. WALKER:
 
          7       Q.   Good morning, sir, will you state your full name,
 
          8    please?
 
          9       A.   Mark Allen Etters.
 
         10       Q.   And Mr. Etters, can you tell us by whom you are employed
 
         11    and what you do for that company?
 
         12       A.   I work for Marriott International at the Courtyard by
 
         13    Marriott located on Arrowood Road.  I'm the general manager of
 
         14    the hotel.
 
         15       Q.   And that hotel which you manage, that's here in
 
         16    Charlotte, is that correct?
 
         17       A.   Yes, sir.
 
         18       Q.   How long have you worked as the general manager of the
 
         19    Courtyard by Marriott hotel at that location?
 
         20       A.   About two and a half years, sir.
 
         21       Q.   What are your general duties as manager of that
 
         22    particular hotel?
 
         23       A.   I run the hotel from the operational standpoint and I
 
         24    report directly to Marriott International about all of the
 
         25    events of the hotel.
 
 
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          1       Q.   As part of your duties and responsibilities, do you have
 
          2    access to former employee files?
 
          3       A.   Yes, sir.
 
          4       Q.   At my request, did I ask you to look into whether or not
 
          5    your hotel at that location at one time or another employed the
 
          6    defendant in this case, Mark, Barnette?
 
          7       A.   Yes.
 
          8       Q.   And would you tell the members of the jury what your
 
          9    investigation showed?
 
         10       A.   We show that he did work at the hotel.  He worked as a
 
         11    night auditor in our hotel, and he left our employment 3-10-95.
 
         12       Q.   And when did he begin employment at that hotel?
 
         13       A.   He was there about a year, I believe it was April
 
         14    of '94.
 
         15       Q.   What were his responsibilities as the night auditor at
 
         16    your hotel?
 
         17       A.   The night auditor, he worked the evening shift, which is
 
         18    from 11:00 at night until 7:00 in the morning, and he reconciles
 
         19    the hotel's receipts on a daily basis.  He was a full-time
 
         20    employee.  He balances the daily records of the hotel.
 
         21       Q.   Who was his direct supervisor while he was at that
 
         22    position?
 
         23       A.   Ed Brumfield was the previous general manager at the
 
         24    hotel.
 
         25       Q.   Was there a Scott Zehner employed by the hotel at that
 
 
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          1    time?
 
          2       A.   Yes, sir, that's correct.
 
          3       Q.   And was he there at the time the defendant was working
 
          4    at your hotel?
 
          5       A.   Yes, sir, he was.
 
          6       Q.   What was Mr. Zehner's position?
 
          7       A.   He was the front desk manager.
 
          8            MR. WALKER:  I don't have any other questions, Your
 
          9    Honor.
 
         10            THE COURT:  Cross?
 
         11            MR. LAUGHRUN:  No questions, Judge.
 
         12            MR. WALKER:  Your Honor, the government calls Lori
 
         13    Quinn.
 
         14                             LORI LEE QUINN,
 
         15    being first duly sworn, was examined and testified as follows:
 
         16                           DIRECT EXAMINATION
 
         17            BY MR. WALKER:
 
         18       Q.   Would you state your full name, please?
 
         19       A.   Lori Lee Quinn.
 
         20       Q.   And Ms. Quinn, by whom are you employed?
 
         21       A.   Camelot Music, Incorporated.
 
         22       Q.   And what do you do for Camelot Music, Incorporated?
 
         23       A.   I'm manager of employee relations and recruiting.
 
         24       Q.   Is Camelot Music, Incorporated, is that a chain music
 
         25    store?
 
 
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          1       A.   Yes, it is.
 
          2       Q.   How many stores do you have in the United States?
 
          3       A.   320.
 
          4       Q.   Do you have a store or stores in Roanoke, Virginia?
 
          5       A.   Yes, we do.
 
          6       Q.   Tell me what your primary responsibilities and duties
 
          7    are with your title at Camelot Music company?
 
          8       A.   I manage the entire employee relations function, which
 
          9    includes overseeing employment records.  I handle all recruiting
 
         10    for corporate positions.
 
         11            THE COURT:  Excuse me just a minute.
 
         12            THE CLERK:  Just back off on the microphone, thank you.
 
         13            THE COURT:  Pull that microphone, just sit back a little
 
         14    bit from it.
 
         15            MR. WALKER:  It's real sensitive.  You can just sit back
 
         16    there and talk.
 
         17            THE WITNESS:  Okay.  Employee issues that arise, I
 
         18    oversee the record retention department of all employment files
 
         19    of --
 
         20            BY MR. WALKER:
 
         21       Q.   Do those include former employment files?
 
         22       A.   Yes.
 
         23       Q.   If someone works for one of your stores, do you keep
 
         24    records of that employee's employment application?
 
         25       A.   Yes, we do.
 
 
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          1            MR. WALKER:  May I approach the witness, Your Honor?
 
          2            THE COURT:  Yes, sir.
 
          3            BY MR. WALKER:
 
          4       Q.   I want to show you what has been marked as Government's
 
          5    Exhibit 13, it consists of three pages, and I will ask you if
 
          6    you can identify that, and if so, what is it?
 
          7       A.   The application for employment from Camelot Music, it's
 
          8    the first two pages, and the third page is the resume.
 
          9       Q.   Okay.  And at my request, did you research your former
 
         10    employee files for possible employment for the defendant in this
 
         11    case, Aquilia Marcivicci Barnette?
 
         12       A.   Yes.
 
         13       Q.   And did you retrieve that particular document, that is,
 
         14    that employment application and resume that have you in front of
 
         15    you?
 
         16       A.   Yes.
 
         17       Q.   Is that document kept on file with your company in the
 
         18    ordinary course of business?
 
         19       A.   Yes.
 
         20            MR. WALKER:  Your Honor, I would move that document into
 
         21    evidence, that being Government's Exhibit 13.
 
         22            THE COURT:  13 will be admitted.
 
         23            BY MR. WALKER:
 
         24       Q.   Referring your attention now to that employment
 
         25    application, does it indicate, if you would, the date that
 
 
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          1    Mr. Barnette first applied or began employment with your company
 
          2    in Roanoke?
 
          3       A.   The application was completed 5-19-95 -- I believe
 
          4    that's 4-19-95.
 
          5       Q.   Did you bring your records with you?
 
          6       A.   Yes, I did.
 
          7       Q.   Do you want to refer to those -- this is a copy, is that
 
          8    correct?
 
          9       A.   Yes, it is.
 
         10       Q.   Do you have the original of that document?
 
         11       A.   Yes.
 
         12       Q.   If you want to refer to those, you may do so.
 
         13       A.   Mr. Barnette started his employment with Camelot on 3-20
 
         14    of '95.
 
         15       Q.   That was March 20th of 1995?
 
         16       A.   Yes.
 
         17       Q.   And at which store was Mr. Barnette employed?
 
         18       A.   Number 185, Valley View Mall in Roanoke, Virginia.
 
         19       Q.   And what was he employed, what was his capacity of
 
         20    employment?
 
         21       A.   He started as a sales associate.
 
         22       Q.   And what happened after that?
 
         23       A.   He was promoted to assistant manager in November of '95,
 
         24    and then his employment was separated January 25th of 1996.
 
         25       Q.   So the employment ended in January of 1996?
 
 
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          1       A.   Yes.
 
          2       Q.   I will give you your documents back.  And in his
 
          3    employment application on the document identified as
 
          4    Government's Exhibit 13, did Mr. Barnette indicate his reasons
 
          5    for seeking employment?
 
          6       A.   Yes.
 
          7       Q.   What was written on the form?
 
          8       A.   I just relocated to Roanoke area, I would love the
 
          9    opportunity to join the Camelot team, I am also a great guy.
 
         10       Q.   Let me ask you one other question.  In the personnel
 
         11    data portion of this application, did he list his home
 
         12    residence?
 
         13       A.   Yes, he did.
 
         14       Q.   And what was the residence listed?
 
         15       A.   1616 Keswick Avenue, Northeast, Roanoke, Virginia,
 
         16    24012.
 
         17            MR. WALKER:  I don't have any other questions, Your
 
         18    Honor.
 
         19            THE COURT:  Cross?
 
         20            MR. LAUGHRUN:  Thank you, Judge Potter, no questions.
 
         21            THE COURT:  Thank you.  Call your next witness.
 
         22            MR. WALKER:  May I pass Government's Exhibit 13 as I
 
         23    call the next witness?
 
         24            THE COURT:  Yes.
 
         25            MR. WALKER:  Your Honor, the government calls Thomas
 
 
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          1    Hodges.
 
          2                            THOMAS H. HODGES,
 
          3    being first duly sworn, was examined and testified as follows:
 
          4                           DIRECT EXAMINATION
 
          5            BY MR. WALKER:
 
          6       Q.   Sir, if you will sit back normally in that chair, that
 
          7    microphone is very sensitive, would you state your full name?
 
          8       A.   Thomas H. Hodges.
 
          9       Q.   And Mr. Hodges, what do you do for a living?
 
         10       A.   Run the Electrolux store in Roanoke.
 
         11       Q.   You run the, pardon me?
 
         12       A.   Electrolux.
 
         13       Q.   And the Electrolux store is what type of business?
 
         14       A.   It's a vacuum cleaner business.
 
         15       Q.   What do you do there at that store, do you have a
 
         16    particular title?
 
         17       A.   I manage the store.
 
         18       Q.   Were you managing the store back in April of 1996 and
 
         19    from that point up until the present time?
 
         20       A.   Yes.
 
         21       Q.   Do you recall at a point back in February of 1996 in
 
         22    which you conducted an interview with an individual named Mark
 
         23    Barnette?
 
         24       A.   Yes.
 
         25       Q.   Do you see that person in the courtroom today?
 
 
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          1       A.   Yes.
 
          2            THE COURT:  Could you speak up just a little bit?
 
          3            THE WITNESS:  Yes.
 
          4            BY MR. WALKER:
 
          5       Q.   As a part of your duties as the manager of the
 
          6    Electrolux store, do you meet with potential employees?
 
          7       A.   Yes, I do.
 
          8       Q.   And explain the process that one would go through to
 
          9    apply for a position with your business.
 
         10       A.   Well, basically you take a resume, find out a little bit
 
         11    about the people, tell them a little bit about what we do, take
 
         12    them out to look at the business, sit down and talk to them.  If
 
         13    they feel like that that's something they could learn to do,
 
         14    would enjoy doing it, then we sit down and fill out a formal
 
         15    application as far as employment.
 
         16       Q.   And did you eventually hire Mr. Barnette?
 
         17       A.   Yes, I did.
 
         18       Q.   In what position was he hired, what was he hired to do?
 
         19       A.   Sales and service.
 
         20       Q.   When you say sales, is that sales to the public?
 
         21       A.   Sales to the public, servicing equipment that's already
 
         22    out there.
 
         23       Q.   Did he complete an employment application with you?
 
         24       A.   Yes, he did.
 
         25            MR. WALKER:  May I approach the witness, Your Honor?
 
 
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          1            THE COURT:  Yes, sir.
 
          2            BY MR. WALKER:
 
          3       Q.   Let me show you Government's Exhibit 14, it consists of
 
          4    two pages, and I will ask you if you can recognize that
 
          5    document, and if so, what is it?
 
          6       A.   Yes, that's the standard documents that they fill out
 
          7    that goes into Atlanta, Georgia as far as employment.
 
          8       Q.   And is that particular application, is that the
 
          9    application that you referred to that you completed with the
 
         10    defendant?
 
         11       A.   Yes, it is.
 
         12       Q.   It consists of two pages, is that correct?
 
         13       A.   Yes.
 
         14       Q.   Okay.  And at what time or what date was that employment
 
         15    application completed?
 
         16       A.   It was on February 15th of '96.
 
         17       Q.   Of 1996?
 
         18       A.   Uh-huh.
 
         19       Q.   Did he indicate what his residence was there in Roanoke
 
         20    when he interviewed with your company?
 
         21       A.   Keswick Avenue, Northwest -- Northeast, Roanoke.
 
         22       Q.   And did he give a number for the Keswick Avenue?
 
         23       A.   1616, I believe is what that says.
 
         24       Q.   At some time, did the defendant's employment with your
 
         25    company come to an end?
 
 
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          1       A.   Yes, it did.
 
          2       Q.   And when was that?
 
          3       A.   That was sometime between April the 10th and the 15th.
 
          4       Q.   Of 1996?
 
          5       A.   Uh-huh.
 
          6       Q.   And did you talk with the defendant about that?
 
          7       A.   He had called and he had equipment checked out and he
 
          8    called me and asked me to come over and pick up the equipment,
 
          9    because he was in the process of trying to move at that
 
         10    particular time.
 
         11       Q.   Did you go over to his apartment on Keswick Avenue?
 
         12       A.   Yes, I did.
 
         13       Q.   What did you see when you went to that location?
 
         14       A.   I saw a loading truck.  I believe it was two gentlemen
 
         15    that was there.  I am thinking one of them is his dad.
 
         16       Q.   Did you see the defendant there?
 
         17       A.   Yes.
 
         18       Q.   And what were they doing with this loading truck?
 
         19       A.   He was getting his equipment out.  I believe there was
 
         20    also a police officer there at the time.
 
         21       Q.   Did you know where the defendant was going to live, did
 
         22    you ever have a conversation with him about that?
 
         23       A.   He wrote down an address of where he was moving to, to
 
         24    send his final check to him.
 
         25       Q.   And what was that, Charlotte, North Carolina?
 
 
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          1       A.   It was in Charlotte, North Carolina.
 
          2            MR. WALKER:  Your Honor, I would move admission of
 
          3    Government's Exhibit 14 and I don't have any other questions of
 
          4    this witness.
 
          5            THE COURT:  It may be admitted.  Cross?
 
          6            MR. LAUGHRUN:  Thank you, Judge Potter.
 
          7                            CROSS-EXAMINATION
 
          8            BY MR. LAUGHRUN:
 
          9       Q.   Mr. Hodge, the address he wrote down, was that 3413 West
 
         10    Boulevard, Charlotte?
 
         11       A.   I believe that's -- I don't have the information with
 
         12    me, I believe it is, but I think you have a copy of the address
 
         13    that he wrote down.
 
         14       Q.   Now, you hired Mark, you never saw any violent
 
         15    tendencies in him, did you?
 
         16       A.   As far as at work in the work situation, I never had any
 
         17    customer complaints or anything of that nature.
 
         18       Q.   And, in fact, he wasn't your best salesmen and wasn't
 
         19    your worst salesmen, is that a fair statement?
 
         20       A.   He really wasn't there long enough to really learn our
 
         21    business, but he was average.
 
         22       Q.   Now, when he got ready to move back to Charlotte, he
 
         23    called you and asked to come to the Keswick apartment to pick up
 
         24    your equipment, did you not?
 
         25       A.   Yes, he did.
 
 
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          1       Q.   That was the equipment you entrusted him to go out and
 
          2    demonstrate the product line, things like that, is that right?
 
          3       A.   That's correct.
 
          4       Q.   No allegation of any theft or anything when he was
 
          5    working with you, is that a fair statement?
 
          6       A.   I think he was like short of one quart of shampoo or
 
          7    something, and he took care of that and we mailed his last check
 
          8    to him.
 
          9       Q.   No other problems with stealing or anything like that,
 
         10    is that correct?
 
         11       A.   Not that I know of.
 
         12       Q.   Mr. Hodge, do you recall an awards banquet in
 
         13    Blacksburg, Virginia that took place while Mark was in your
 
         14    employment and he went with Robin Williams and attended that
 
         15    banquet and you met her, do you recall that incident?
 
         16       A.   I recall the banquet that we went to.  I can't really
 
         17    recall who he brought.  There was a lot of people there, and I
 
         18    can't really recall who he brought with him.
 
         19       Q.   You recall Mark being there, is that right?
 
         20       A.   Uh-huh.
 
         21            MR. LAUGHRUN:  Thank you, Mr. Hodge.  Thank you, Judge
 
         22    Potter.
 
         23            THE COURT:  No redirect?
 
         24            MR. WALKER:  Just briefly, Your Honor.
 
         25                          REDIRECT EXAMINATION
 
 
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          1            BY MR. WALKER:
 
          2       Q.   Mr. Hodges, again on Government's Exhibit 14, when he
 
          3    was applying to your company, did you ask him if he had ever
 
          4    been convicted of a crime?
 
          5       A.   It's listed on the sheet, and I think he checked no.
 
          6       Q.   Look at that document and make sure what he checked.
 
          7       A.   Okay, the section here, have you ever been convicted of
 
          8    a crime, is marked no.
 
          9       Q.   And you also on Page 2 of that form there is a place, is
 
         10    there not, for reasons for leaving prior places of employment,
 
         11    is that right?
 
         12       A.   Yes, sir.
 
         13       Q.   And referring your attention to the first one listed
 
         14    there, former employee, Camelot Music, he indicated a reason for
 
         15    leaving Camelot Music.  What did the defendant list?
 
         16       A.   I can't quite make that out on the copy.  I can't read
 
         17    it.
 
         18            MR. WALKER:  Judge, I don't have any other questions of
 
         19    Mr. Hodges.
 
         20            THE COURT:  Thank you, sir.  Call your next witness.
 
         21            MR. WALKER:  May I have just a moment, Your Honor?
 
         22            (Pause.)
 
         23            MR. WALKER:  Your Honor, the government would call Dan
 
         24    Wilbur.
 
         25                             DANIEL WILBUR,
 
 
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          1    being first duly sworn, was examined and testified as follows:
 
          2                           DIRECT EXAMINATION
 
          3            BY MR. WALKER:
 
          4       Q.   Sir, state your name and tell us what you do for a
 
          5    living.
 
          6       A.   Daniel Wilbur, branch manager for Penske Truck Leasing.
 
          7       Q.   How long have you been a manager for Penske Truck
 
          8    Leasing?
 
          9       A.   I've been the branch manager here in Charlotte for a
 
         10    year.  I've been with Penske for eight years.
 
         11       Q.   And Penske is a -- you can rent moving trucks from your
 
         12    company, is that correct?
 
         13       A.   That's correct.
 
         14       Q.   Was your -- do you work here in a particular office in
 
         15    Charlotte?
 
         16       A.   I work over on I-85 and Billy Graham Parkway.
 
         17       Q.   Was that office open and in business back in April of
 
         18    1996?
 
         19       A.   Yes, it was.
 
         20       Q.   Does your company keep records of when an individual
 
         21    rents a moving truck from your company?
 
         22       A.   Yes, it does.
 
         23       Q.   Are those kept as a part of the ordinary course of
 
         24    business with your company?
 
         25       A.   Yes.
 
 
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          1            MR. WALKER:  May I approach the witness, Your Honor?
 
          2            THE COURT:  Yes, sir.
 
          3            BY MR. WALKER:
 
          4       Q.   I'm going to show you Government's Exhibit 15.  I will
 
          5    ask you to take a look at Government's Exhibit 15, and tell me
 
          6    if you can recognize what that is, and if so, what is it?
 
          7       A.   What we refer to it as a household rental agreement.
 
          8    It's what's filled out when someone rents a truck.
 
          9       Q.   Who is that particular agreement with?
 
         10       A.   The agreement is with Barnette, Aquilia.
 
         11       Q.   And where was the agreement entered into, at which
 
         12    Penske store?
 
         13       A.   That was rented from our agent up in Roanoke, Virginia,
 
         14    3301 Cove Road.
 
         15       Q.   Was it a truck that was rented?
 
         16       A.   I'm sorry?
 
         17       Q.   It was a rental truck that was rented?
 
         18       A.   Yes.
 
         19       Q.   And where was the destination of the rental truck?
 
         20       A.   The destination was to be turned in at 2600 I-85 South.
 
         21       Q.   That's here in Charlotte, correct?
 
         22       A.   That is correct.
 
         23            MR. WALKER:  Your Honor, I would move the admission of
 
         24    that exhibit, Government's Exhibit 15.
 
         25            THE COURT:  All right, sir.  Mr. Wilbur, you are the
 
 
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          1    custodian of those records, are you?
 
          2            THE WITNESS:  Yes, we keep them as well as Atlanta, yes.
 
          3            THE COURT:  They will be admitted.
 
          4            MR. WALKER:  I don't have any other questions, Your
 
          5    Honor.
 
          6            THE COURT:  Cross?
 
          7            MR. WILLIAMS:  No questions.
 
          8            THE COURT:  Thank you, sir, call your next witness, you
 
          9    may step down.
 
         10            MR. CONRAD:  Your Honor, may we take a morning break at
 
         11    this time?
 
         12            THE COURT:  All right, sir.  Little early, but we'll
 
         13    take it.  Members of the jury, do not discuss the case among
 
         14    yourselves.  Go back and see if Ms. Grier has made you some good
 
         15    coffee at this point.
 
         16            Excuse me, did she have an exhibit in her hand, Sammy?
 
         17    Sammy, go back and tell them to bring the exhibit back and put
 
         18    it on the chair.
 
         19            (The Clerk retrieves exhibit from a juror.)
 
         20            (The jury left the courtroom.)
 
         21            THE COURT:  Recess until 10:50.
 
         22            (Brief recess.)
 
         23            THE COURT:  Call the jury.
 
         24            (The jury returned to the courtroom.)
 
         25            THE COURT:  Members of the jury, I may have neglected to
 
 
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          1    tell you, if you have an exhibit which has been passed around to
 
          2    you in your hand whenever we have a recess, just leave it on
 
          3    your chair, because I don't want my exhibits back in the jury
 
          4    room until you get ready for your deliberations.  You will have
 
          5    them all back there for your deliberations, so do not try to
 
          6    take them back and preview them right now.
 
          7            One other thing I want to mention to you as a practical
 
          8    matter, if you go out at lunch, you probably ought to get your
 
          9    raincoat because I understand the it's going to raining hard
 
         10    this afternoon.  It may not be, but that's what the weather man
 
         11    says.
 
         12            All right, call your next witness.
 
         13            MR. CONRAD:  The United States would call Sara
 
         14    Aldridge.
 
         15                             SARAH ALDRIDGE,
 
         16    being first duly sworn, was examined and testified as follows:
 
         17                           DIRECT EXAMINATION
 
         18            BY MR. CONRAD:
 
         19       Q.   Would you state your name for the jury and spell your
 
         20    last name for the court reporter?
 
         21       A.   Sara Aldridge, A-L-D-R-I-D-G-E.
 
         22       Q.   Sarah, how are you employed?
 
         23       A.   I'm a registered nurse at the University of Virginia.
 
         24       Q.   And in what department at the University of Virginia?
 
         25       A.   The burn unit.
 
 
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          1       Q.   How long have you been a registered nurse?
 
          2       A.   Three years.
 
          3       Q.   And have those three years all been in the burn unit?
 
          4       A.   Two and a half of them.
 
          5       Q.   Okay.  And in April of 1996, what were your duties?
 
          6       A.   I was a staff nurse in the burn unit at the university.
 
          7       Q.   And what does a staff nurse in the burn unit at UVA do?
 
          8       A.   We provide total care for burn patients and chronically
 
          9    wound care parents.
 
         10       Q.   When you say total care, what are you referring to?
 
         11       A.   We provide the wound care for the burns, we provide the
 
         12    daily care, the medications, the assessments, the monitoring.
 
         13       Q.   And wound care, what would be involved with wound care?
 
         14       A.   In relation to a burn, we tank our patients each day.
 
         15    That's a process in which we cleanse the wound, remove any dead
 
         16    flesh, repair the wound bed for grafting.
 
         17       Q.   Now, tanking, that's a pretty descriptive term, what is
 
         18    involved in that process?
 
         19       A.   Tanking is a word that's kind of a carry over from years
 
         20    ago when a patient was submerged in a large pool of water.
 
         21       Q.   Uh-huh.
 
         22       A.   The way our unit tanks a person is on a large stretcher
 
         23    that's lined with plastic, take them into a special procedure
 
         24    room in which they are -- we use general flow water to wash down
 
         25    their wounds with an antimicrobial agent called Sure Cleanse.
 
 
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          1    Then we debride or remove the flesh that is not going to heal
 
          2    and rewrap the wounds with various products according to
 
          3    how -- what stage of healing they are in.
 
          4       Q.   And this process, is it a painful process?
 
          5       A.   Yes, sir.  Without medication, it would be very painful.
 
          6       Q.   Is that because of the debriding or the removal of flesh
 
          7    that you were referring to?
 
          8       A.   Not so much the removal of the flesh as it is the depth
 
          9    of the burn.  A first degree burn or what we would think of as a
 
         10    sunburn is very, very painful.  A second degree burn is also
 
         11    painful.  The deeper the burn or the third degree burn in and of
 
         12    itself initially is not painful, because the nerve endings have
 
         13    been destroyed.  We use strong medications and ample medications
 
         14    that are quick acting, that last a very short period of time,
 
         15    and perform what we call conscious sedation.
 
         16       Q.   What kind of medications are those?
 
         17       A.   One medication we use a called Versed.  It is a
 
         18    benzodiazepine that helps to relieve anxiety.  And the other
 
         19    medication that we actually use for pain is Phentanyl, which is
 
         20    an opioid that is kin to morphine, but it's very quick acting.
 
         21       Q.   In April of 1996, do you recall Robin Williams being a
 
         22    burn patient at the burn center in UVA?
 
         23       A.   Yes, sir.
 
         24       Q.   Relate to the jury how you first met her.
 
         25       A.   Our unit is very small.  Our staff works as a very tight
 
 
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          1    team in that each of us help to provide for all of the needs of
 
          2    each patient.  I first met Robin when she was in her room.  She
 
          3    had already received her first tanking.  She was laying in her
 
          4    room very quiet and still.  She was not responsive to any
 
          5    overtures at conversation for several days.  She just was kind
 
          6    of untrusting of us at first.
 
          7       Q.   How frequent were the tanking procedures administered to
 
          8    her?
 
          9       A.   Once a day.
 
         10       Q.   And as a staff nurse, would you have opportunity to be
 
         11    with her during that time period that she was at the burn
 
         12    center?
 
         13       A.   Yes, sir.
 
         14       Q.   Did you have any conversation with her?
 
         15       A.   Yes, sir, I did.
 
         16       Q.   And relate to the jury any conversation that you had
 
         17    with her.
 
         18            MR. LAUGHRUN:  Objection.
 
         19            THE COURT:  Excuse me, I will sustain that unless we get
 
         20    into something more specific.
 
         21            MR. CONRAD:  Thank you, Your Honor.
 
         22            BY MR. CONRAD:
 
         23       Q.   Did you discuss a protection plan with her?
 
         24       A.   Yes.
 
         25       Q.   Describe for the jury what a protection plan is.
 
 
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          1       A.   Near the end of her stay when we are making our final
 
          2    discharge plans, Robin was due for grafting in the next day or
 
          3    two, I took care of her on an evening night shift.  We were
 
          4    talking about her situation and what her plans were for
 
          5    discharge, where she would go.  She described to me --
 
          6            MR. LAUGHRUN:  Objection.
 
          7            THE COURT:  Wait a minute.
 
          8            BY MR. CONRAD:
 
          9       Q.   In the process of discussing this protection plan, did
 
         10    you ask her about the incident which led to her coming to the
 
         11    UVA burn center?
 
         12       A.   Yes, sir.
 
         13       Q.   And what, if anything, did she tell you about that?
 
         14            MR. LAUGHRUN:  Objection.
 
         15            THE COURT:  Overruled.
 
         16            THE WITNESS:  She told me that she had been in a fire,
 
         17    that it had been started by her boyfriend, she had jumped from a
 
         18    window.  She told me that she wasn't sure whether she should
 
         19    jump, whether he would be waiting for her at the bottom or if
 
         20    she should run through the fire, but she realized she would be
 
         21    engulfed had she run through the fire and she had no choice.
 
         22            BY MR. CONRAD:
 
         23       Q.   Did she tell you anything else about the incident
 
         24    itself?
 
         25       A.   That was the basics of it.
 
 
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          1       Q.   Did she tell you anything with respect to her future
 
          2    plans?
 
          3       A.   Yes, sir.
 
          4       Q.   What did she tell you?
 
          5            MR. LAUGHRUN:  Objection.
 
          6            THE COURT:  Overruled.
 
          7            MR. CONRAD:  Go ahead.
 
          8            THE WITNESS:  She told me that she would be going home
 
          9    with family in the Roanoke area or in southwest Virginia area.
 
         10    She told me -- I asked her specifically if she felt that that
 
         11    was far enough way that she would be safe, to which she told me
 
         12    that it wouldn't matter where she went, that she was not going
 
         13    to be safe.
 
         14            BY MR. CONRAD:
 
         15       Q.   Now, you indicated that she was near the end of her
 
         16    stay, ready for grafting, what did you mean by that?
 
         17       A.   When a person receives a third degree burn, the skin
 
         18    will not regenerate, it will not heal, and skin from another
 
         19    area of the body has to be removed and surgically implanted over
 
         20    the area that has been burned.
 
         21       Q.   Now, so do I understand her course of treatment to be
 
         22    one of trying to get the skin to regenerate for the first part
 
         23    of her stay and the second phase being the skin grafting
 
         24    procedures?
 
         25       A.   Robin had several levels of injury.  The first and
 
 
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          1    second degree burns were promoted to heal and regenerate on
 
          2    their own.  The third degree burns that she received primarily
 
          3    on her hands were not going to heal.  It's fairly obvious after
 
          4    the first 48 hours, and then it's preparing the wound bed.  So
 
          5    we did a little of all of it.
 
          6       Q.   Did she eventually undergo skin grafting?
 
          7       A.   Yes, sir.
 
          8       Q.   And what is involved in that?
 
          9       A.   They are taken to the operating room.  Under general
 
         10    anesthesia, skin is removed, skin and muscle tissue if that is
 
         11    needed,  she needed just skin tissue, is removed usually from a
 
         12    leg in the thigh area.  It's then sutured onto the affected
 
         13    area.  As I recall, hers was what we call a split thickness skin
 
         14    graft meaning that it was just lifted up from, say, if this was
 
         15    the leg, and put here on the back of her hand and sewn down with
 
         16    compression dressings to hold it in place until it adhered.
 
         17       Q.   And as part of her discharge plan, did you discuss with
 
         18    her her future rehabilitation plans?
 
         19       A.   Yes, sir.  She said that she would be receiving
 
         20    follow-up care at the university for the foreseeable future.
 
         21            MR. CONRAD:  That's all I have, Judge.
 
         22            THE COURT:  Cross?
 
         23            MR. WILLIAMS:  No questions, Your Honor.
 
         24            THE COURT:  No cross?
 
         25            MR. WILLIAMS:  No questions.
 
 
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          1            THE COURT:  Thank you.  Call your next witness.
 
          2            MR. WALKER:  Your Honor, the government calls Jacob
 
          3    Freshour.
 
          4                          JACOB BOYD FRESHOUR,
 
          5    being first duly sworn, was examined and testified as follows:
 
          6                           DIRECT EXAMINATION
 
          7            BY MR. WALKER:
 
          8       Q.   Sir, if you will have a seat and lean back in that
 
          9    chair, that microphone is very sensitive in front of you, would
 
         10    you state your full name?
 
         11       A.   Jacob Boyd Freshour.
 
         12       Q.   And Mr. Freshour, what do you do for a living?
 
         13       A.   Manage Quik Pawn Shop.
 
         14       Q.   You manage the Quik Pawn Shop?
 
         15       A.   Yes, sir.
 
         16       Q.   How long have you been the manager of the Quik Pawn
 
         17    Shop?
 
         18       A.   Four years.
 
         19       Q.   And that's -- how many locations are there of your
 
         20    business here in Charlotte?
 
         21       A.   Four in Charlotte.
 
         22       Q.   Back in May, and specifically on May 20th and May 21st
 
         23    of 1996, were you the manager of one of the Quik Pawn shops here
 
         24    in Charlotte?
 
         25       A.   Yes, sir.
 
 
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          1       Q.   Which particular store was that, and if you'll raise
 
          2    your voice just a little bit?
 
          3       A.   The freedom Drive branch.
 
          4       Q.   Did you, turning your attention to the morning of
 
          5    May 20th of 1996, did you on that particular morning have
 
          6    occasion to sell a 12-gauge shotgun to an individual at your
 
          7    pawnshop?
 
          8       A.   Yes, sir.
 
          9       Q.   And was that a Stephens 12-gauge shotgun?
 
         10       A.   Yes, sir.
 
         11       Q.   Would you describe, do you remember if it was in the
 
         12    morning or afternoon that you made that sale?
 
         13       A.   It was in the morning, slightly after we opened.
 
         14       Q.   Pardon me?
 
         15       A.   It was in the morning just slightly after we opened,
 
         16    9:30 maybe.
 
         17       Q.   What do you remember about that sale, if you would tell
 
         18    the members of the jury?
 
         19       A.   It was a pretty uncomplicated sale.  The gentleman just
 
         20    came in and said he was looking for a shotgun.  It wasn't
 
         21    rushed.  We just looked at three or four, and that particular
 
         22    one was, you know, the price range he said he was hunting for.
 
         23    He filled out the yellow form, and very little conversation
 
         24    during the sale.
 
         25       Q.   What name did the person give you?
 
 
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          1       A.   Mario Vonkeith Barnette.
 
          2       Q.   And you mentioned that you filled out some forms.  Are
 
          3    there particular firearm forms, Bureau of Alcohol, Tobacco and
 
          4    Firearm forms that you have to fill out when you complete the
 
          5    sale of a firearm?
 
          6       A.   Yes, sir, there is a yellow form on a shotgun that you
 
          7    fill out.
 
          8       Q.   And tell the members of the jury why it's important for
 
          9    your company to fill those out.
 
         10       A.   So we can track the gun.  It establishes, you know, that
 
         11    the person is not a felon or has a record or anything like that.
 
         12       Q.   Did this person present you with some form of
 
         13    identification, the person who called himself Mario Barnette?
 
         14       A.   Yes, sir.
 
         15       Q.   What form of information did he present you on May 20th
 
         16    of 1996?
 
         17       A.   It was from Virginia, a Virginia driver's license.
 
         18       Q.   Did you have him complete the form that you just
 
         19    described?
 
         20       A.   Yes, sir.
 
         21       Q.   And did that individual leave the store with the gun
 
         22    that you sold him?
 
         23       A.   Yes, sir.
 
         24       Q.   Describe that gun, what type of shotgun was that?
 
         25       A.   It with a pump shotgun, a Stephens.
 
 
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          1       Q.   Long barrel shotgun?
 
          2       A.   Long barrel shotgun.
 
          3       Q.   I want to turn your attention now to the next day, that
 
          4    being May 21st of 1996, did you have an occasion to see that
 
          5    same person again at your store?
 
          6       A.   Yes, sir.
 
          7       Q.   What time of day was it that you saw him again?
 
          8       A.   Roughly the same time, 9:30, quarter to 10:00.
 
          9       Q.   Did you wait on that person again?
 
         10       A.   Yes, sir.
 
         11       Q.   What happened on that occasion?
 
         12       A.   We give a warranty on our guns, used guns of a year.
 
         13    And he brought the gun home, said he took it home, it was
 
         14    malfunctioning, there was a broken part on it and wanted to
 
         15    exchange it for another gun.
 
         16       Q.   Did you talk with him about that?
 
         17       A.   Yes, sir.
 
         18       Q.   And did you allow an exchange for another gun?
 
         19       A.   Yes, sir.
 
         20       Q.   Tell the members of the jury about that transaction.
 
         21       A.   He brought the gun in, and we don't have a gunsmith on
 
         22    premise or any way to fire the guns, and so I just exchanged the
 
         23    gun for a Winchester semiautomatic shotgun, long barrel.
 
         24       Q.   And did you have this person who called himself Mario
 
         25    Barnette then fill out a second ATF form that you described?
 
 
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          1       A.   Yes.  Each gun has to have a yellow form.
 
          2            MR. WALKER:  May I approach the witness, Your Honor?
 
          3            THE COURT:  Yes.
 
          4            BY MR. WALKER:
 
          5       Q.   I want to show you, Mr. Freshour, what has been marked
 
          6    as Government's Exhibits 18A and 18B.  Referring your attention
 
          7    first to Government's Exhibit 18A, would you take a look at 18A
 
          8    and tell me if you recognize that document, and if so, what is
 
          9    it?
 
         10       A.   Yes, sir, it's a document to transfer ownership of the
 
         11    shotgun from us to the customer.
 
         12       Q.   And is that the document that you completed on the first
 
         13    sale of the shotgun that you described?
 
         14       A.   Yes, sir.
 
         15       Q.   Now, referring your -- are those the documents that your
 
         16    company keeps in the regular course of business?
 
         17       A.   Yes, sir.
 
         18       Q.   Explain to the members of the jury how those documents
 
         19    are filled out, in other words, do you complete all of the
 
         20    questions or how is that done?
 
         21       A.   No, the customer completes the first half that gives
 
         22    address, the name and the date of the transaction, answers a
 
         23    series of questions and then their signature.  And then below
 
         24    that, we check a box that says they have identified themselves
 
         25    with a form of I.D., fill out the I.D., the shotgun, the model,
 
 
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          1    the serial number if applicable, caliber, Stephens, and stamp it
 
          2    with our gun permit number and sign it and date it.
 
          3       Q.   Now, you said there was a series of questions on here
 
          4    that the buyer, potential buyer fills out.  Does the person have
 
          5    to fill that out before you will sell them the firearm?
 
          6       A.   Yes, and if they fill it out wrong, we won't sell the
 
          7    firearm.
 
          8       Q.   And when you say you fill it out wrong, what do you mean
 
          9    by that?
 
         10       A.   If they answer a question like, are you a fugitive from
 
         11    justice, if they put yes, then we will not sell them a firearm,
 
         12    and we don't allow them to fill out another one.
 
         13       Q.   But when the person answers yes or no to those
 
         14    questions, does your company do anything to verify a yes or no
 
         15    or do you just look for a yes or no?
 
         16       A.   By law, you just look for a yes or no.
 
         17       Q.   All right.  Now, let me ask this:  What are question
 
         18    number 8A, I believe, could you read that question if that's how
 
         19    you normally ask or is asked of the potential buyer?
 
         20       A.   Are you under indictment or information in any court for
 
         21    a crime punishable by imprisonment for a term exceeding one
 
         22    year, or formal accusation of a crime made by a prosecuting
 
         23    attorney as distinguished from an indictment as presented by a
 
         24    Grand Jury.
 
         25       Q.   And that particular form was filled out by the
 
 
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          1    individual that you sold the first shotgun to who gave you the
 
          2    name Mario Vonkeith Barnette, is that correct?
 
          3       A.   Yes, sir.
 
          4       Q.   And how did that person answer that question?
 
          5       A.   No.
 
          6       Q.   And what is the question right underneath that?
 
          7       A.   Have you been convicted in any court of a crime
 
          8    punishable by imprisonment for a term exceeding one year, and
 
          9    then it says no -- yes answer is necessary if the judge could
 
         10    have given you a sentence of more than one year, a yes answer is
 
         11    not required if you have been pardoned for the crime, or the
 
         12    conviction has been expunged or set aside, or you have had your
 
         13    civil rights restored and under the law where the conviction
 
         14    occurred you are not prohibited from receiving or possessing any
 
         15    firearm.
 
         16       Q.   And in response to that question, have you been
 
         17    convicted in any court of a crime punishable by imprisonment for
 
         18    a term exceeding one year, what answer did the person give you?
 
         19       A.   No.
 
         20       Q.   Referring your attention now to the third question, does
 
         21    that read, are you a fugitive from justice?
 
         22       A.   Yes.
 
         23       Q.   And what answer did this person who called himself
 
         24    Mario, what answer did he give?
 
         25       A.   No.
 
 
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          1       Q.   You mentioned that you fill out part of the form.  Which
 
          2    part of that form do you fill out?
 
          3       A.   Section B.
 
          4       Q.   Okay, would you explain that to the members of the jury,
 
          5    how that's done?
 
          6       A.   The first part of Section B, it says to be completed by
 
          7    the transferor or the seller, and it says the person described
 
          8    in Section A is either known to me or has identified himself or
 
          9    herself to me in the following manner.  You know, we do not --
 
         10    we don't ever let anybody check, is known to me.  They always
 
         11    have to have I.D.  And then type of identification, whether it's
 
         12    a driver's license or a state-issued I.D., has to have name,
 
         13    date of birth, place of residence and signature, the number on
 
         14    the identification itself, and then the next section underneath
 
         15    that lists the type of gun it would be, pistol, revolver, rifle,
 
         16    shotgun, et cetera, model number.
 
         17       Q.   Let me slow you down there just a little bit.  Referring
 
         18    your attention first to question number 9, type of
 
         19    identification the potential buyer gives you, is that a block
 
         20    that you complete?
 
         21       A.   Yes, sir.
 
         22       Q.   And this is the form for the first sale, is that
 
         23    correct, on the 20th?
 
         24       A.   Yes.
 
         25       Q.   And did you -- what did you indicate as the form of
 
 
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          1    identification that this person gave you?
 
          2       A.   I put Virginia, and then actually --
 
          3       Q.   Did you put Virginia identification?
 
          4       A.   I put Virginia I.D.  We don't have to notate necessarily
 
          5    D.L. or I.D., we just do it kind of for our records.
 
          6       Q.   Okay.  Describe again briefly the type of shotgun that
 
          7    you sold during the first transaction.
 
          8       A.   It was a Stephens shotgun, model 77-B, 12-gauge, just a
 
          9    regular long barrel pump shotgun.
 
         10            MR. WALKER:  Your Honor, I would move that exhibit into
 
         11    evidence, Government's Exhibit 18A.
 
         12            THE COURT:  Let it be admitted.
 
         13            BY MR. WALKER:
 
         14       Q.   Now, sir, you indicated that you saw the same person the
 
         15    next day, is that correct?
 
         16       A.   Yes, sir.
 
         17       Q.   And you said that was shortly after you opened, is that
 
         18    right?
 
         19       A.   Yes, sir.
 
         20       Q.   And you had him complete the same type of form a second
 
         21    time?
 
         22       A.   Yes, sir.
 
         23       Q.   Referring your attention to Government's Exhibit 18B, is
 
         24    that the second firearm transaction form that you completed with
 
         25    the same person on the 21st, the second day?
 
 
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          1       A.   Yes, sir.
 
          2       Q.   And was that required in order for you to sell the
 
          3    exchange of the first shotgun for the second shotgun?
 
          4       A.   Yes, sir.
 
          5       Q.   And did you go through the same procedure with this
 
          6    person as you had on the day previously?
 
          7       A.   Yes, sir.
 
          8       Q.   In other words, he answered the questions on the top of
 
          9    the form?
 
         10       A.   Yes, sir.
 
         11       Q.   And did you complete the questions on the bottom of
 
         12    form?
 
         13       A.   Yes, sir.
 
         14       Q.   I want to turn your attention to box number 9, where on
 
         15    the second form you wrote in the type of identification the
 
         16    person gave you.  Is that different than the type of
 
         17    identification you placed on Government's Exhibit 18A, the first
 
         18    day of the transaction?
 
         19       A.   The same number, I notated it for our records as a
 
         20    driver's license instead of an I.D.
 
         21       Q.   Could you have made a mistake on that?
 
         22       A.   I would say yes, sir, I would say it's a driver's
 
         23    license.
 
         24       Q.   Okay.  What was the serial number of the second shotgun
 
         25    that you sold the defendant?
 
 
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          1       A.   N 868530.
 
          2       Q.   And was that second shotgun a pump shotgun?
 
          3       A.   No, sir, a semiautomatic.
 
          4       Q.   Was it a long barrel shotgun?
 
          5       A.   Yes, sir.
 
          6       Q.   How did this person pay for these weapons?
 
          7       A.   Cash.
 
          8       Q.   And what was the amount of the sale?
 
          9       A.   With tax, $211.99.
 
         10            MR. WALKER:  Your Honor, I would also move admission of
 
         11    Government's Exhibit 18B.
 
         12            THE COURT:  Let it be admitted.
 
         13            BY MR. WALKER:
 
         14       Q.   Sir, if you were to see a replica or an exact model of
 
         15    the first gun that you sold to this person on the 20th, would
 
         16    you be able to recognize that and indicate that to the jury?
 
         17       A.   Yes, sir.
 
         18            MR. WALKER:  Your Honor, I would ask Agent Modzelewski
 
         19    to assist me in front of the jury and have the witness come
 
         20    down.  I want to show him an exhibit of that type of weapon if I
 
         21    may.
 
         22            THE COURT:  What exhibit number is this?
 
         23            MR. WALKER:  Your Honor, this would be Government's
 
         24    Exhibit 31E-2.
 
         25            THE COURT:  Step down, sir.
 
 
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          1            BY MR. WALKER:
 
          2       Q.   If you will step down and I will ask Agent Modzelewski
 
          3    to come around, and I will show you Government's Exhibit 31E-2.
 
          4    If you will take a look at that item, it's been disengaged, and
 
          5    indicate whether that is exactly like the shotgun that you first
 
          6    sold this person who called himself Mario Vonkeith Barnette?
 
          7       A.   Yes.
 
          8       Q.   Okay, if you would turn around to the members of the
 
          9    jury.
 
         10       A.   Yes, sir.
 
         11       Q.   And that's a pump action shotgun, is that correct?
 
         12       A.   Yes.
 
         13       Q.   You may return to your seat.
 
         14            MR. WALKER:  I don't have any other questions for this
 
         15    witness, Your Honor.
 
         16            THE COURT:  All right, sir.  Cross?
 
         17                            CROSS-EXAMINATION
 
         18            BY MR. WILLIAMS:
 
         19       Q.   Mr. Freshour, your shop is in Charlotte, North Carolina?
 
         20       A.   Yes, sir.
 
         21       Q.   You were selling a gun to somebody with an
 
         22    identification from Roanoke, Virginia?
 
         23       A.   Yes, sir.
 
         24       Q.   Did you ask that person why he was buying a gun in
 
         25    Charlotte, North Carolina when he had a license and
 
 
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          1    identification from Virginia?
 
          2       A.   No, sir.  With a shotgun, as long as you live in a
 
          3    bordering state, you can purchase a shotgun in any bordering
 
          4    state to your state.
 
          5       Q.   When you take these applications and you sell people
 
          6    guns, the purpose of the application and the questions in the
 
          7    application is to inform you, if I'm correct, and correct me if
 
          8    I'm wrong, that you want to know something about this person
 
          9    before you decide whether or not to sell them a gun, correct?
 
         10       A.   Yes, sir.
 
         11       Q.   And on that application, you have questions about their
 
         12    prior criminal record and other things about the person,
 
         13    correct?
 
         14       A.   Yes, sir.
 
         15       Q.   Do you rely 100 percent on the answers that these people
 
         16    give you before you decide to sell them a weapon?
 
         17       A.   Yes, sir, that's the law.
 
         18       Q.   That's the law.  Did you or do you make any attempts
 
         19    whatsoever to go down to the police department with these
 
         20    applications and check the police records to see if they have a
 
         21    record, either here or in the State of Virginia?
 
         22       A.   No, sir, we do what is required by law.
 
         23       Q.   If you knew that Mr. Barnette had a record, as indicated
 
         24    on the questionnaire, would you have sold him that gun?
 
         25       A.   No, sir.
 
 
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          1            MR. WILLIAMS:  No further questions.
 
          2            THE COURT:  Redirect?
 
          3            MR. WALKER:  Briefly.
 
          4                          REDIRECT EXAMINATION
 
          5            BY MR. WALKER:
 
          6       Q.   On both of the forms, did the person who bought those
 
          7    two guns from you indicate his home address?
 
          8       A.   Yes, sir.
 
          9       Q.   And what, if you will tell the jury, what address was
 
         10    listed?
 
         11       A.   1616 Keswick Avenue, Northeast, Roanoke, Virginia.
 
         12       Q.   And is that on both forms?
 
         13       A.   Yes, sir.
 
         14            MR. WALKER:  Your Honor, I would ask permission to pass
 
         15    these to the jury.
 
         16            THE COURT:  You haven't moved the admission of 31E-2
 
         17    yet, I don't think.
 
         18            MR. WALKER:  As well, move that into admission as well.
 
         19            THE COURT:  Very well, it will be admitted.
 
         20            MR. WALKER:  I don't have any other questions, Your
 
         21    Honor.
 
         22            THE COURT:  Thank you, sir, you may come down.  Call
 
         23    your next witness.
 
         24            MR. CONRAD:  United States would caller Earlene
 
         25    Thompson.
 
 
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          1                            EARLENE THOMPSON,
 
          2    being first duly sworn, was examined and testified as follows:
 
          3                           DIRECT EXAMINATION
 
          4            BY MR. CONRAD:
 
          5       Q.   Would you please state your name for the jury, spelling
 
          6    your last name for the court reporter?
 
          7       A.   Earlene Thompson, T-H-O-M-P-S-O-N.
 
          8       Q.   Ms. Thompson, where do you live?
 
          9       A.   904 Loudon, apartment A.
 
         10       Q.   You are going to have to speak up a little bit, okay?
 
         11       A.   904 Loudon in Roanoke, apartment A.
 
         12       Q.   And how long have you lived there?
 
         13       A.   Two years.
 
         14       Q.   And were you living there in April of 1996?
 
         15       A.   Yes, I was.
 
         16       Q.   How long had you been living at that -- strike that.
 
         17            How long had you been living there in April of 1996?
 
         18       A.   About a month.
 
         19       Q.   About a month?
 
         20       A.   Uh-huh.
 
         21            MR. CONRAD:  May I approach the witness, Your Honor?
 
         22            THE COURT:  Yes, sir.
 
         23            BY MR. CONRAD:
 
         24       Q.   Ms. Thompson, can you come off the witness stand and
 
         25    come up with me, please?
 
 
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          1       A.   (Witness complies.)
 
          2       Q.   I'm going to show you what has been marked for
 
          3    identification as Government's Exhibits 21P, 21O, 21R and 21Q,
 
          4    and do you recognize those photographs?
 
          5       A.   (Witness nods head.)  This is my apartment there.
 
          6       Q.   Are these aerial photographs and ground-level
 
          7    photographs of Loudon Avenue?
 
          8       A.   Yes, it is.
 
          9       Q.   And do they fairly and accurately show your
 
         10    neighborhood?
 
         11       A.   Yes, it does.
 
         12            MR. CONRAD:  Your Honor, move admission of Government's
 
         13    Exhibits 21P, O, R and Q.
 
         14            THE COURT:  They will be admitted.
 
         15            MR. CONRAD:  Okay -- stay right here.
 
         16            BY MR. CONRAD:
 
         17       Q.   Turning your attention to Government's Exhibit 21P, and
 
         18    if you would stand on the side right here so all of the jurors
 
         19    can see, would you show the jury where your apartment is?
 
         20       A.   Right here and right here (indicating), right here and
 
         21    right here, in front of this car.
 
         22       Q.   Now, is it a duplex?
 
         23       A.   Yes, it is.
 
         24       Q.   Do you know Ms. Bertha Williams?
 
         25       A.   Yes, I do.
 
 
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          1       Q.   Can you show the jury where on this photograph
 
          2    Ms. Williams' house is?
 
          3       A.   Right there, there, (indicating) there and down the
 
          4    street.
 
          5       Q.   And do you know who lives -- this is a duplex right
 
          6    here, is that correct?
 
          7       A.   Yes.
 
          8       Q.   As you face Loudon Avenue, do you live on the left or
 
          9    the right?
 
         10       A.   Left.
 
         11       Q.   Okay.  So you -- on this side of the building
 
         12    (indicating)?
 
         13       A.   Right.
 
         14       Q.   Do you know who lives on your right?
 
         15       A.   Yes.
 
         16       Q.   Who lives there?
 
         17       A.   Sonji Hill.
 
         18       Q.   Has she lived there the whole that you've been there?
 
         19       A.   Yes.
 
         20       Q.   Does anyone live with you at 904 Loudon Avenue?
 
         21       A.   My daughters.
 
         22       Q.   How old are they?
 
         23       A.   They're 8 and 12.
 
         24       Q.   Does anybody live with Ms. Hill as far as you know in
 
         25    the other apartment?
 
 
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          1       A.   Her daughters.