P R O C E E D I N G

[In the Superior Court of Gwinnett County, Lawrenceville, Georgia; 9:00 a.m., Thursday, August 31, 1995; the STATE OF GEORGIA v. MICHAEL HAROLD CHAPEL, 93-B-1818-6; Criminal Jury Trial, Judge Fred A. Bishop, Jr., presiding.]

THE COURT:  Ready Mr. Moore?

MR. MOORE:  Yes, Your Honor.

THE COURT:  Ready, Mr. Porter?

MR. PORTER:  The state's ready, Your Honor.

THE COURT:  Bring the jury in, please.

[The jurors were escorted to the courtroom.]

THE COURT:  Good morning, ladies and gentlemen.

[Jurors respond]

THE COURT:  Everybody doing okay this morning?  Good. 

Mr. Moore, call your first witness, please.

MR. MOORE:  Your Honor, the first thing I would do is, I've shown this to Mr. Porter, I would tender Defendant's Exhibit Number 98, which is an affidavit from Windy Howe of the Law Enforcement Technology Center from the U. S. Department of Justice certifying the Defendant's Exhibit Number 99, which is a 1992 Model Year Patrol Vehicle Testing done by the Michigan state police, and we would tender Defendant's Exhibits Number 98 and 99 at this time.

THE COURT:  What is 99?

MR. MOORE:  99 is a -- it's a booklet put out by the U. S. Department of Justice, 1992 Model Year Patrol Vehicle Testing.

THE COURT:  Mr. Porter?

MR. PORTER:  Your Honor, the state would agree that it is a true and correct copy.  We do not agree that the data is accurate, and it has not been established, or we don't know whether the data is accurate, and I don't think a proper foundation has been laid for the admission.

THE COURT:  Mr. Moore?

MR. MOORE:  Your Honor, I would tender it to the Court and let the Court look at it and make that determination.

MR. PORTER:  We stipulate that it is an official publication of the United States Department of Justice.  We stipulate that it is, in fact, what it says it is, but I don't think, number one, the accuracy of the data has been found.  And second of all, I think it's only admissible for the record.

THE COURT:  For what purpose is the affidavit offered?

MR. MOORE:  The affidavit and the booklet put out by the Department of Justice are offered for the purpose of having an expert witness, Your Honor, testify regarding the performance of that vehicle and various distance and time computations.  Now, we have a witness standing by that we can fly in if necessary.

THE COURT:  Well, in this instance, what's been marked as Defendant's 98, the affidavit, it would not appear to be a -- I mean, it would appear to me that that affidavit would not make it a certified document admissible on the basis of being a certified document.  And if it's an affidavit, it seems to me there's an issue as to whether or not what does it say can it be cross-examined as is it inadmissible.  Would you approach the bench, please.

[Counsel approached the bench, and a conference was held outside hearing of the jury, as follows]

THE COURT:  I guess my question is, where are we headed with it?

MR. MOORE:  Well, I have an engineer, Your Honor, who is going to testify, based on the performance of that vehicle, about times and distances and everything.  I've got a witness from Michigan that we can fly in.  It's probably going to cost about a thousand dollars to do it, but I mean he's standing by to come in if necessary.

MR. PORTER:  Your Honor, I think in this circumstance if the witness testifies and he uses that document, then that's fine.  That's admissible testimony just like any other expert who testifies to the basis of his opinion using certain data, and if I have the opportunity to attack that.  I'm standing here today, I don't have any real objection to that going into the record as the basis of the expert opinion, but I can't -- I'm not going to agree to the accuracy of the data.  I think that's a subject for cross-examination.  That's a subject for verification by the expert.

MR. MOORE:  Your Honor, I'm not contending it ought to go out to the jury or anything, merely that the expert could use that --

MR. PORTER:  I'm not quibbling that it's an authentic document.

THE COURT:  Okay.  All right.  So, well, maybe we can reach a stipulation here that satisfies everybody.  What you want is the document used in conjunction with the testimony of the expert.

MR. MOORE:  Yes, Your Honor.

THE COURT:  And you want to be able to -- you don't have any problem with that document going in as an exhibit for the record only, and then you use it on direct or cross-examination, but you're not stipulating to the --

MR. PORTER:  Content.

THE COURT:  -- to the accuracy of the contents.

MR. PORTER:  That's correct.

THE COURT:  Mr. Moore?

MR. MOORE:  Your Honor, that should be fine.

THE COURT:  Okay.  So stipulated.

MR. MOORE:  Your Honor, we'd call Mary Ann White to the stand.

THE COURT:  Let me ask, with respect to Defendant's 98 and 99, the affidavit and the document marked Defendant's 99, I believe the stipulation is that those both be admitted for the record to use in conjunction with examination of your witness or on cross-examination or with respect to any witness the state may wish to call in rebuttal.  Is that correct?

MR. MOORE:  That's correct, Your Honor.  We intend to offer an expert who will give opinions based on matters in the booklet there, Defendant's Exhibit Number 99.

THE COURT:  All right.  But there is no stipulation as to the accuracy or the contents in Defendant's 99?

MR. PORTER:  That is correct, Your Honor.  We agree that that is a true and correct copy of that particular document, and it may be the basis for an expert opinion, but we reserve the right to question the basis of that opinion, and we do not stipulate that those are true and correct numbers as they apply to the defendant's vehicle.

THE COURT:  All right.  Mr. Moore, is that the stipulation?

MR. MOORE:  Yes, Your Honor.

THE COURT:  So stipulated.  Which witness do you call next?

MR. MOORE:  Mary Ann White.

[The witness was called to the courtroom.]

THE COURT:  Ms. White, if you'll take the stand up here.

[The witness stepped to the stand.]

THE COURT:  I believe you've been sworn, and you remain under oath.

THE WITNESS:  Yes, sir.

MR. MOORE:  Your Honor, I've had this plastic bag marked as Exhibit Number 101.  It contains various miscellaneous papers.  At this time we intend not to get the various papers inside marked individually, but if we do cross-examine anybody about them or use those papers individually, Mr. Porter and I have agreed we'll take them out and have them marked as we use them.

THE COURT:  All right.  What's the -- what are the documents?  What are they about?

MR. MOORE:  It's various documents that were taken from Mr. Chapel's car.

THE COURT:  All right.  So the plastic bag is marked as 100, and the documents --

MR. MOORE:  D-101, Your Honor.

THE COURT:  All right, D-101.  Is that -- restate what 101 is, please.

MR. MOORE:  That's the plastic bag containing the various miscellaneous documents.  It's labeled 'miscellaneous papers.'

THE COURT:  All right.  Collectively it's 101?

MR. MOORE:  Yes, your Honor.  And if we use any of them individually we'll get them marked as we take them out.

THE COURT:  Okay.

MR. MOORE:  You were already sworn, I believe, but would you hold up your right hand, please.  Do you solemnly swear the testimony you're about to give before this Court will be the truth, the whole truth, and nothing but the truth, so help you God?

THE WITNESS:  I do.

Whereupon,

     MARY ANN WHITE

having been called as a witness and duly sworn, was examined and testified, as follows:

     DIRECT EXAMINATION

BY MR. MOORE:

Q.   Would you state your name, please?

A.   Mary Ann White.

Q.   Okay.  And Technician White, I'm going to show you what's been marked as Defendant's Exhibit Number 101 and ask if you can identify that.

A.   These are miscellaneous papers that I got from Unit 197, and this is my handwriting.

Q.   And you gathered those on what date?

A.   4/29/93, I believe.

Q.   And you gathered all those various items and placed them in that plastic bag which is labeled Defendant's Exhibit 101?

A.   Yes.

Q.   And each of them came out of Unit 197?

A.   Yes, they did.

Q.   I'm going to show you two other documents, Defendant's Exhibit 72 and 73, and ask you if you can identify those.

A.   No.  I don't remember these.

Q.   You don't know whether those were in the plastic bag or not?

A.   No, I don't know.

Q.   Okay. 

 MR. MOORE:  Your Honor, we have two exhibits here, Defendant's Exhibit 72 and 73, which were removed from Mr. Chapel's car, and Mr. Porter and I have agreed to stipulate that these were removed from the plastic bag that Technician White has.  And we would tender those at this time, Defendant's Exhibits 72 and 73.

MR. PORTER:  Your Honor, that is correct.  We would stipulate that those documents were removed from the bag recovered by Technician White, and they were removed to show them to defense counsel, I believe, outside the Gwinnett County police department on July the 25th of 1995.

THE COURT:  Any objection to Defendant's 72 and 73 being admitted?

MR. PORTER:  No.  We have no objection.

THE COURT:  Defendant's 72 and 73 are admitted without objection.

BY MR. MOORE:

Q.   Technician White, without reading what's in those, could you identify what Defendant's Exhibit 72 and 73 are?

A.   They're incomplete incident reports.

Q.   And is that the type of incident report that's normally filled out by an officer when he goes out on a call?

A.   As far as I know it is, yes.

Q.   And those, it appears, have never been filed; is that correct?

A.   That's correct.

Q.   Now, when you gathered up the papers and everything out of Officer Chapel's car, did you gather up everything in there?

A.   As far as I know I did, yes.

Q.   And you placed it either in that plastic bag, or else some of the items were in a briefcase; is that correct?

A.   I didn't see the briefcase.

Q.   You never did see the briefcase?

A.   No.

Q.   It had already been removed at the time you ---

A.   Yes.

Q.   Did you gather any other items up?  I believe you removed the seat, you testified earlier; is that correct?

A.   Yes, I did.

Q.   Did you gather up any other items to be sent to the crime lab?

A.   From -- from Unit 197?

Q.   Yes, ma'am.

A.   Just the seat and the arm rest.

Q.   That's the only thing you gathered and sent to the crime lab?

A.   That's correct.

Q.   I'm going to show you what's been marked as Defendant's Exhibit Number 76 and ask you if you've ever seen that item before.

A.   I don't remember it.

Q.   Would you have any knowledge as to how it got into a briefcase in the car?

A.   No.

Q.   I'm going to show you what's been marked as Defendant's Exhibit 102 and ask if you can identify that.  There's a tag on the side there.

A.   This is the pursuit pack that I took out of Officer Chapel's car.

Q.   And tell the jury what is a pursuit pack?  What's it for?

A.   It's for holding papers and forms.  It fits over the seat and you can keep blank forms and ticket books and that sort of thing in it.

Q.   Could you come down and show the jury how it fits over the seat?

A.   [Witness complies]

Q.   Is that the way it was in Officer Chapel's car in Unit 197 when you retrieved it?

A.   Yes, it was.

Q.   And did it contain anything at that time when you went into his car?

A.   Yes.

Q.   And what was in it?

A.   Papers, ticket books, ink pens, just miscellaneous personal items.

Q.   And you did the Luminol of the car; is that correct?

A.   Yes, I did.

Q.   Okay.  Did you Luminol the pursuit pack or any of the things there?

A.   No, I didn't.

Q.     So none of that was checked or sent to the crime lab?            A.   No.

Q.     Okay.

MR. MOORE:  Your Honor, at this time I tender Defendant's Exhibit 102.

MR. PORTER:  No objection, Your Honor.

THE COURT:  Defendant's 102 admitted without objection.

BY MR. MOORE:

Q.   I'm going to show you Defendant's Exhibit Number 103 and ask you if you can identify this.

A.   It looks familiar to me.  I believe I got it from Unit 197.

Q.     Technician White, I'm going to show you a couple of property records and let you look at it and see if they refresh your memory regarding --

A.   Yes.  I listed a plastic figurine on the property sheet.

Q.   And do you remember where you removed that from in the car?

A.   No, I'm sorry, I don't.

Q.   Was it up on the dash of the car?

A.   I don't remember.  I don't remember if it was sitting on the dash or not.

Q.   If you look at it on the bottom it's got a Velcro type strip here where it sticks onto something?

A.   Yes, it does.

Q.   And you don't recall that sitting up on the dash of the car?

 MR. PORTER:  Your Honor, he's leading the witness.  It's his witness.

THE COURT:  [No response]

BY MR. MOORE:

A.   [Continuing]  I'm sorry.  I don't remember where it came from out of the car.

Q.   Okay.  But you did take that out of Officer Chapel's car?

A.   Yes.

MR. MOORE:  Your Honor, at this time we'd tender Defendant's Exhibit 103.

THE COURT:  Any objection?

MR. PORTER:  No, your Honor.

THE COURT:  Defendant's 103 is admitted without objection.

BY MR. MOORE:

Q.   I'm going to show you Defendant's Exhibit Number 104 and ask you if you can recognize that.

A.   Yes.  I listed a shoulder holster that was made out of cloth on my property sheets.

Q.   Okay.  And did you remove that from Officer Chapel's car?

A.   Yes.

MR. MOORE:  At this time, Your Honor, we'd tender D-104.

MR. PORTER:  Your Honor, at this time we would object.  There's been no -- the only evidence is that it's been removed from the patrol car.  There's been nothing to connect it to this defendant in terms of ownership.

THE COURT:  Mr. Moore?

MR. MOORE:  Your Honor, if it's removed from this patrol car by this technician, there's a presumption that things that are in the vehicle in Georgia belong to the person in possession of that vehicle, and we would contend that it should be admitted.

MR. PORTER:  Your Honor, that only applies to the owner of the vehicle.  It does not apply to someone who has a vehicle assigned, particularly in the case of a police officer who may have evidence, who may have items that belong to someone else.  I don't think a patrol car fits under that exception of the ownership presumption.

THE COURT:  Mr. Moore?

MR. MOORE:  Your Honor, we'd just tender it to the Court.

THE COURT:  Defendant's 104 is admitted over objection.

BY MR. MOORE:

Q.   Now, Technician White, did you remove a gun belt like that from Officer Chapel's car?

A.   Yes, I did.

Q.   Okay.  Was that gun belt sent for any testing or anything?

A.   No.

Q.   I'm going to show you what's been marked as Defendant's Exhibit Number 105 and ask you if you can identify that.

A.   Yes.  I believe that's the Living Bible that I removed from Officer Chapel's car.

Q.   And was that removed on the date -- the same date as the other items in 1993?

A.   Yes, it was.

Q.   And do you know where in the car that was removed from?

A.   No, I'm sorry, I don't.

Q.   But you did remove that from his car?

A.   Yes.

Q.   I'm going to show you Defendant's Number 106 and ask if you can identify that.

A.   Yes.  I listed a pair of -- let me find it -- leather and mesh fingerless gloves that was -- that I removed from Officer Chapel --

Q.   Did you remove those from Unit 197, Officer Chapel's car, in 1993?

A.   Yes, I did.

 MR. MOORE:  Your Honor, at this time we'd tender Defendant's Exhibit 105 and 106.

 THE COURT:  Would you approach the bench, please?

[Counsel approached the bench, and a conference was held, as follows.]

THE COURT:  Let me ask, insofar as the contents of the car, I'm not anxious to refuse things that may have some relevance.  I guess my question is, is the fact that everything that came out of that car, including the lint from the glove compartment or something, does the fact that it's in the car make it admissible?

MR. MOORE:  Your Honor, we believe that particularly the gloves and everything are going to be relevant.  There's going to be other testimony regarding those at a later time.

MR. PORTER:  Your Honor, I think there's two questions, particularly about 106, the Bible.  We've already had a discussion about the Bible and the access of jurors to Bibles, and the defense is putting in a Bible.  We'd argue that it's not relevant.

MR. MOORE:  Your Honor, I'm not contending the Bible should go out to the jury.  I'm not asking it go out, just the fact that it was in his vehicle.  They've gone into the contents of the vehicle in detail.

MR. PORTER:  In relevant -- for the relevant portions of testimony.

THE COURT:  Well, that's my question, I guess.  The fact that it's in the vehicle, it seems to me -- it sure makes me inclined to liberally construe what's relevant if it comes out of the vehicle.  But I think the simple fact that anything comes out of the -- out of the vehicle doesn't in and of itself mean it ought to be admitted into evidence.

MR. MOORE:  Your Honor, they selectively tested certain things in the vehicle and didn't test other things, and I think we have a right to show what they didn't test as well as what they did.  I mean the state showed what they did test.

MS. ROGAN:  Yeah.  I mean their allegation is that there was blood inside the car.  I think we're entitled to show the number of other things that were inside the car that don't have blood on them.

THE COURT:  What other items are we going to be looking at?

MS. ROGAN:  How many, did you say?

THE COURT:  What other items are we going to be looking at out of the car?

MS. ROGAN:  Well, there's quite a list.  There was a lot of stuff in that car.

MR. PORTER:  Well, Your Honor, there's been no testimony regarding the location of those items and their relevancy as to the testing.  Maybe the pursuit pack.  But they haven't said where the gloves were.  If it was in the glove compartment, what relevance is it that it wasn't tested?  If it was in the trunk, what relevance is it that it wasn't tested?

THE COURT:  Well, that's my question.

MR. PORTER:  I mean particularly --

MS. ROGAN:  We think there is some relevance.

MR. PORTER:  Well, I understand they think that, but they haven't shown it.

THE COURT:  Well, I think my inclination is let's go ahead and identify them, where they came from, and then when you have some connection, when there's some relevance demonstrated, then we will rule whether or not they're coming in or not.

MR. PORTER:  Your Honor --

THE COURT:  It seems to me -- it just seems to me that if we have 500 items that came out of the trunk or out of the wheel well or out of the glove compartment or anyplace else, just the simple fact that they're in the car doesn't make them admissible.

MS. ROGAN:  Well, but her testimony, Your Honor, is that she just removed the stuff from the interior of the car on the seats.  She didn't go into the trunk, she'd said previously, and I don't believe she ever said she went into the glove compartment, so that's not even an issue.  This is stuff that was on the seats.

THE COURT:  Well, I mean I don't know what's -- that's what I'm asking.  I don't know where we're going.

MR. MOORE:  Well, Your Honor, I don't know whether I can ask her whether or not she conducted any tests on them if they're not in evidence.  I mean I'm not going to be allowed to question her about whether tests were run on them --

MR. PORTER:  Your Honor, the state would object to this parade of stuff in front of the jury if it -- particularly if it's going to be subsequently ruled out.  I think if we're going to -- if we're going to follow that procedure, we ought to ask the jury to step out, let Mr. Moore make his proffer with Mary Ann White --

THE COURT:  Well, on one hand, you know, I don't want to handcuff the defendant from putting up their case.  On the other hand, if it's not relevant and it's not admissible, then it ought not to be piled up in front of the jury.  So, you know, that's sort of my quandary.

MR. MOORE:  But, Your Honor, I can't very well cross-examine the witness about whether they tested it or not unless --

MR. PORTER:  He's not cross-examining this witness, Your Honor.  This is his witness.

MR. MOORE:  Your Honor, she's a police department witness, and we believe we'd have the right -- she's not a friendly witness to the defense.

MR. PORTER:  I don't think there's been any --

THE COURT:  At this point she's your witness.  At this point.

MR. MOORE:  I understand.

THE COURT:  What other items are you going to have her identify?  Where are we going?  What other kinds of items are we talking about?

MS. ROGAN:  Well, she removed probably thirty items from the patrol car, much of which was returned because the state didn't think it was relevant to its case.  That doesn't mean we don't think it's relevant to our case.  And we have it here in court and we'd like her to identify the items that are on her inventory sheet that she removed from the interior of the car.

THE COURT:  Well, the fact that -- the fact -- maybe he's got the key to his house or his apartment and that was removed from him or removed from the car and given back to his folks, does that make that relevant evidence to put here in front of the jury just because they took it from the car?

MS. ROGAN:  It is, under our theory, if they didn't test it for blood, and it was in a location in the car that it could have -- we're going to have other witnesses testify as to where in the car these things were even though she doesn't remember.

MR. PORTER:  Your Honor, that only gets -- that only moves further to necessitate the offer of proof outside the presence of the jury.  This is prejudicial, particularly evidence they can't get in.  The car had to be cleaned up and returned to the fleet.

MR. MOORE:  Your Honor, I don't have any problem with doing it outside the presence of the jury if the Court wants to, but we do feel like --

THE COURT:  I think that might be good.  Let's just see where we're going and then just sort of get the lay of the land and lay out some boundaries here, what we're about to do.  And I think maybe that will -- maybe that will help everybody.  Okay.  Let's do that.

[Bench conference concluded]

THE COURT:  We're going to take up a matter that won't require the presence of the jury.  Mr. Allen, I'm going to ask you to take the jurors out for a few minutes.  We'll recommence in a moment.

[The jurors were excused from the courtroom.]

THE COURT:  Mr. Moore, where -- where are we going with the items in the car?

MR. MOORE:  Your Honor, the state has put forth before the jury a theory that blood was -- somehow got into Mr. Chapel's car as a result of Ms. Thompson being killed.  We intend to show that there were numerous items that were located in close proximity to the area where they claim the blood was, and we intend to question witnesses about whether or not any of these items were tested.

The state's been allowed to put in evidence of tests which they selected a certain area they wanted to test.  We think we're allowed to put in items in close proximity to show whether or not they tested those items, whether any tests were conducted on them which might have -- might have excluded Mr. Chapel or might have shown that -- in fact, we don't know what it would have shown because we don't believe they tested them, and we think we have a right to question about that.

And furthermore, Your Honor, the evidence in this case, certain items, for instance, the gloves that we had there, we intend to present evidence that Mr. Chapel wore those all the time, particularly when it was a rainy time, and it was a rainy night when this occurred, and determine whether or not the state ever tested those gloves or not, whether or not any tests were ever conducted on them.

THE COURT:  What other items are we talking about offered in that vein?

MR. MOORE:  Your Honor, my proposal would be we've got a plastic container here of various items, and to save time, my plan was to have the plastic container marked and then have Technician White see which, if any, items she could identify, and then we can -- if she can identify them, then we can discuss whether or not they're admissible.  All these were removed from Mr. Chapel's car when she did the --

THE COURT:  All right.  Do you want to go ahead and do that now?

MR. MOORE:  Yes, sir.

     DIRECT EXAMINATION RESUMED - JURY OUT

BY MR. MOORE:

Q.    Technician White, I'm going to show you what's been marked as Defendant's Exhibit Number 107 and ask you if you would look through that and see which, if any, items in there you can identify.  And if you'd tell us when you find one you can identify, I'll get it marked, each one, as you -- if there is anything you can identify in Defendant's Exhibit 107.

A.   Okay.  First of all, the box is listed on the property sheet.  This -- and I know where this was.  It was in the trunk.

Q.   So you did remove Defendant's Exhibit Number 107 from Mr. Chapel's car?

A.   Yes.

Q.   And did you use that as a storage container to put other items in?

A.   Yes, I think I did.  I don't see these listed separately.  This is the metal clipboard.

Q.   Is that something you can identify?  If it is, I'll get it marked.

A.   Yes.

 [Defendant's Exhibit 108 was marked for identification by the court reporter.]

BY MR. MOORE:

Q.   The metal clipboard that you just referred to, that's Defendant's Exhibit Number 108, can you identify that?

A.   Yes.  I removed it from Officer Chapel's car.   This is the metal ticket book holder.  [Presenting]

Q.   Now, D-108, that's the metal clipboard.  Do you remember where you removed that from in the car?

A.   No, I don't.

Q.   You had picked out Defendant's Exhibit --

 [Defendant's Exhibit 109 was marked for identification by the court reporter.]

BY MR. MOORE:

Q.   You had picked out Defendant's Exhibit 109 as something you could identify, too.  Could you identify that?

A.   Yes.  That's the metal ticket book holder.

THE COURT:  Okay.  What number is that, Mr. Moore?

MR. MOORE:  109, Your Honor.

BY MR. MOORE:

Q.   And did you remove that from Unit 197, Mr. Chapel's car, in 1993?

A.   Yes, I did.  And here's the $6.31.  [Presenting]

 MR. MOORE:  Let me get that marked. 

 [Defendant's Exhibit 110 was marked for identification by the court reporter.]

BY MR. MOORE:

Q.   Okay.  Showing you Defendant's Exhibit Number 110 that's been marked now, could you identify that?

A.   Yes.  That's $6.31 that I removed from Officer Chapel's car.

Q.   Okay.  Do you remember where you removed that money from?

A.   No, I -- I don't remember.  I think it was just scattered around.  It wasn't all together.  This is a book of raffle tickets that I removed from the vehicle.  [Presenting]

Q.   Okay.  The book of raffle tickets, Defendant's Exhibit Number 111, could you -- is that the raffle tickets you're referring to?

A.   Yes.

Q.   And did you remove that from Officer Chapel's car, Unit 197, in 1993?

A.   Yes, I did.

Q.   Okay.  We'll get that marked.    A.     Yeah, that's a -- that's the TV set I removed.

[Defendant's Exhibit 112 was marked for identification by the court reporter.]

BY MR. MOORE:

Q.   I'm going to show you what's been marked as Defendant's Exhibit Number 112.  Is that the TV set you referred to?

A.   Yes.

Q.   And did you remove that from Mr. Chapel's car, Unit 197, in 1993 when you searched it?

A.   Yes, I did.

Q.   And do you remember where Defendant's Exhibit Number 112, the TV set, was located?

A.   I believe it was in the trunk.

Q.   It was in the trunk. 

A.   Let's see.  This is the glasses case that I removed.

 [Defendant's Exhibit 113 was marked for identification by the court reporter.]

BY MR. MOORE:

Q.   Okay.  Now, the glasses case has been marked as Defendant's Exhibit Number 113.  Is that the glasses case you're referring to?

A.   Yes.

Q.   Is that the one you removed from Mr. Chapel's car, Unit 197, in 1993 when you searched it?

A.   Yes.  And here's a box of two cigars.

 [Defendant's Exhibit 114 was marked for identification by the court reporter.]

BY MR. MOORE:

Q.   Okay.  The two cigars you referred to in a box, Defendant's Exhibit Number 114, is that the same ones you're referring to?

A.   Yes.

Q.   And did you remove those from Mr. Chapel's car, Unit 197, when you searched it in 1993?

A.   Yes, I did.  This is a cup holder, and I removed it, also.

[Defendant's Exhibit 115 was marked for identification by the court reporter.]

BY MR. MOORE:

Q.   The cup holder you referred to, Defendant's Exhibit Number 115, consists of two pieces; is that correct?

A.   Yes.

Q.   And is that the cup holder you removed from Mr. Chapel's car, Unit 197, in 1993?

A.   Yes.

Q.   Where was it located?  Was it in the car or --

A.   I don't recall.  I don't -- I don't think it was hanging up.  Okay.  Here's two right-hand gloves that I recovered.

 [Defendant's Exhibits 116 and 117 were marked for identification by the court reporter.]

 THE COURT:  Is that 116?

BY MR. MOORE:

Q.   There's two separate gloves, so I'm going to show them to you separately.  Defendant's Exhibit Number 116, could you identify that?

A.   Yes.  That's one of the gloves that -- one of the right-hand gloves that I removed.

Q.   Okay.  You removed that from Mr. Chapel's car, Unit 197, in 1993 when you searched it?

A.   Yes, I did.

Q.   Defendant's Exhibit Number 117, would you look at that, please?

A.   Yes.  That's another right-hand glove.

Q.   And did you remove that from Mr. Chapel's car, Unit 197, in 1993 when you searched it?

A.   Yes, I did.  [Presenting]  Coffee mug that I found in the car.

 [Defendant's Exhibit 118 was marked for identification by the court reporter.]

BY MR. MOORE:

Q.   Okay.  I'll show you what's been marked as Defendant's Exhibit 118 and ask you if you could identify that.

A.   Yes.  That's the coffee mug that I removed from Officer Chapel's car.

Q.   Okay.  And that's when you searched Unit 197 in 1993; is that correct?

A.   That's correct.  And these are two pairs of sunglasses.

[Defendant's Exhibits 119 and 120 were marked for identification by the court reporter.]

BY MR. MOORE:

Q.   I'll show you what's been marked as Defendant's Exhibit Number 119.  Can you identify that?

A.   Yes.  That's a pair of sunglasses that I got out of Officer's Chapel's car.

Q.   Okay.  And that was Unit 197 which you searched in 1993?

A.   Unit 197, correct.

Q.   Defendant's Exhibit Number 120, could you identify that?

A.   That's the other pair of sunglasses that I got out of Officer Chapel's car.

Q.   Okay.  And was that also in 1993 when you searched it?

A.   Yes.  There's a clipboard.

[Defendant's Exhibit 121 was marked for identification by the court reporter.]

BY MR. MOORE:

Q.   I show you Defendant's Exhibit Number 121.  Is that the clipboard you referred to that you removed from Officer Chapel's car in 1993 when you searched it?

A.   Yes, it is.  And a Crown Royal bag.

[Defendant's Exhibit 122 was marked for identification by the court reporter.]

BY MR. MOORE:

Q.   Defendant's Exhibit Number 122, which is a Crown Royal bag, is that the bag you removed from Officer Chapel's car in 1993 when you searched it?

A.   Yes, it is.

Q.   Do you remember where it was located?

A.   No, I don't.  I'm sorry.  This is the miscellaneous personal items and papers, and I believe that this may have fallen out.  It has been opened.  Looks like a light bulb -- a little -- a light bulb.

Q.   Okay.  Did this --

A.   Yeah, I believe they -- I believe they came out of there.  Mr. Moore?

Q.   Yes?

A.   This may have come out of it, too, because I don't see it listed separately.  It's a cigarette lighter.

Q.   Do you know whether it did or not?

A.   No, I don't.  The bag's been opened, and I really don't know.

Q.   If you don't know then, I won't try to put it in.  Just leave it.

A.   Okay.

[Defendant's Exhibits 123 and 124 were marked for identification by the court reporter.]

BY MR. MOORE:

Q.   I'm going to show you what's been marked as Defendant's Exhibit Number 123, which is a plastic bag containing some things.  Could you identify that?

A.   This is what I listed as miscellaneous items, personal items on when I first -- that I got out of Officer Chapel's car.

Q.   Okay.  And that was in 1993 when you searched it; is that correct?

A.   Correct.

Q.   I show you Defendant's Exhibit Number 124 and ask if you can identify that.

A.   I got this out of the -- Officer Chapel's car.  I believe it came out of here.

Q.   You believe that originally was in Defendant's Exhibit Number 123, the plastic bag?

A.   Yes, sir.

Q.   And that's an envelope containing what?

A.   It looks like a light bulb, like a flash light bulb.  There's a hand mirror.

[Defendant's Exhibit 125 was marked for identification by the court reporter.]

BY MR. MOORE:

Q.   Okay.  Showing you Defendant's Exhibit Number 125, what's been marked, is that the hand mirror you're referring to?

A.   Yes.

Q.   Okay.  And did you remove that from Officer Chapel's car in 1993 when you searched it?

A.   Yes, I did.  A package of soup.

[Defendant's Exhibit 126 was marked for identification by the court reporter.]

THE COURT:  Do we have a 124?

MR. MOORE:  That was 124, Your Honor, the envelope containing a light bulb.

THE COURT:  What was 123?

MR. MOORE:  123 was a plastic bag of miscellaneous papers, Your Honor.

THE COURT:  Okay.  You marked the white bag separately as 124 [sic]?

MR. MOORE:  Yes, sir. 

THE COURT:  Okay.

MR. MOORE:  Yes, sir.

BY MR. MOORE:

Q.   Showing you Defendant's Exhibit 126, is that the package of soup that you just referred to?

A.   Yes, it is.

Q.   And was that removed from Officer Chapel's car when you searched it in 1993?

A.   Yes, it was.

Q.   And is that all the items that you --

A.   I found two packs of gum.  I don't see them listed.  And these are not listed, I don't believe, on either one of these sheets, but I remember listing them.  There's probably another sheet.

Q.   I'm going to give you another property sheet.  That will perhaps refresh your memory.  And let you look at it before you --

A.   Here's the two packages of gum.

 [Defendant's Exhibits 127 and 128 were marked for identification by the court reporter.]

BY MR. MOORE:

Q.   Defendant's Exhibit Number 127, is that one of the packages of gum that you're referring to?

A.   Yes, sir, it is.

Q.   Is that -- did you remove that from Officer Chapel's car in 1993 when you searched it?

A.   Yes.

Q.   And Defendant's Exhibit Number 128, that's another package of chewing gum.  Did you remove that from Officer Chapel's car in 1993 when you searched it?

A.   Yes, I did.  Apparently I miscounted these.  I listed ten brown envelopes, and now I'm counting eleven.

Q.   So the brown --

A.   They're -- right.

[Defendant's Exhibit 129 was marked for identification by the court reporter.]

BY MR. MOORE:

Q.   I'm going to hand you what's marked as Defendant's Exhibit 129, which is a group of brown manila envelopes.  And I've added a paper clip here, which is not on there, to hold them together.  But other than the paper clip, can you identify those?

A.   Yes.  I believe these are the envelopes that I removed from Officer Chapel's car.

Q.   Okay.  Were they removed in 1993 when you searched the vehicle?

A.   Yes, they were.

Q.   Is that everything you can identify, Technician White?

A.   Yes.

THE COURT:  Are these items that were retained by the state after the taking of these items that were returned over to the defendant?  Mr. Moore?

MR. MOORE:  I'm sorry, Your Honor?

THE COURT:  Were these items given back to the defendant or --

MR. MOORE:  They were returned to the defendant, Your Honor.

THE COURT:  Okay.  These have not been in the custody of the police department since his arrest or at least shortly after?

MR. MOORE:  They were in the custody of the police department up until the time of the hearings and the search warrant, and at that time a number of items were returned to the family.

THE COURT:  All right.

MR. MOORE:  The state, at that time, decided they were not going to use the items so they were returned.

THE COURT:  That includes all of these that we're in the process of marking now?

MR. MOORE:  That's correct, Your Honor.

THE COURT:  Okay.  All right.  Go ahead, please.

[Defendant's Exhibit 130 was marked for identification by the court reporter.]

BY MR. MOORE:

Q.   I'm going to show you what's been marked as Defendant's Exhibit Number 130 and ask if you can identify that.

A.   This is an evidence tag that I filled out.

Q.   Okay.  Do you know what that was used for?

A.   I believe it was tied to the box.

Q.   Okay.  You pointed to Defendant's Exhibit 107, which is a plastic box.  Was that tied to the box?

A.   Yes, I believe it was.

Q.   Okay.  And was that attached when you searched the car in 1993?

A.   Yes.

Q.   Now, Technician White, why did you remove all those items that we've talked about, from D-107 up through D-129, all these items spread out in front of you?  Why did you remove those from Mr. Chapel's car?

A.   Because they were -- most of them were personal property.

Q.   Okay.  Were you looking for anything that might be evidence?

A.   No.

Q.   What were your instructions when you searched the car?

A.   To search for a car wash receipt and do presumptive blood tests.

Q.   And were your instructions to -- did you have any instructions about what to seize or what not to seize?

A.   No.

Q.   Nobody gave you any instructions?

A.   No.

Q.   Then tell us why you decided to take these items in?

A.   Because they were personal property, and I was just getting the rest of the stuff out of the car.

Q.   Did anyone discuss with you whether or not to have any of these items tested?

A.   No.

Q.   And did you make a list of these and make it available for the investigating officers in the case?

A.   Yes.

Q.   And that would have been -- who did you turn that over to?

A.   Well, actually, when I turn in the property sheets, these, they make copies.  I mean they're -- sorry.  I can't think of the word.  It's this kind of paper that makes copies.  And they get a copy back from the property room.

Q.   Do you know whether or not any tests were conducted on any of the items, D-107 through D-129?

A.   No.

Q.   Particularly with respect to D-106, which are gloves, were any tests conducted on those, to your knowledge?

A.   No.

Q.   And did you at any time use the chemical Luminol on any of those items in front of you there --

A.   No.

Q.   -- D-106 through D-129?

A.   No.

THE COURT:  What is 107, Mr. Moore?

MR. MOORE:  I thought it was, too, Your Honor, but the gloves apparently had been marked before the box, and D-106 is the gloves.

THE COURT:  But 107 is the box?

MR. MOORE:  It's the box.

THE COURT:  Okay.  I just did not know.

MR. MOORE:  I didn't realize the gloves had been marked earlier, but the other items did come out of the box.

BY MR. MOORE:

Q.   Did you perform any other kind of chemical test on any of the items D-106 through D-129?

A.   No, I didn't.

Q.   Did anyone request that you perform any tests on them?

A.   No.

THE COURT:  Were all these items taken from the -- where in the car were these items removed?

THE WITNESS:  Some of them were in the trunk, and some were in the pursuit pack in the front seat.

THE COURT:  Do you know which was taken from the trunk and which from the seat?

THE WITNESS:  No, sir.  I know that this was in the trunk and the coffee mug and the TV set. 

THE COURT:  All right, that's fine.  Go ahead, Mr. Moore.

THE WITNESS:  I'm sorry.

BY MR. MOORE:

Q.   Now, when you first observed Mr. Chapel's car, did you have to remove a number of items that are in front of you from the seat before you could test it with Luminol?

A.   Yes.

Q.   Okay.  Do you remember which items you removed from the seat?

A.   Well, of course I removed the pursuit pack and all the papers that were in it.  I don't remember everything that was in the front seat.

Q.   Was the front seat neat and clean or was it cluttered or what did it look like when you got the car?

A.   It was -- I mean it had some papers in it, but it wasn't -- it wasn't extremely cluttered.

MR. MOORE:  That's all we have at this time, your Honor.

THE COURT:  Mr. Porter?

     CROSS EXAMINATION - JURY OUT

BY MR. PORTER:

Q.   Mary Ann, I just want to ask you some questions to complete the record.  In regard to the gloves which have been labeled State's Exhibit Number 107 -- 106, do you recall where in the car you found those?

A.   No, I don't.

Q.   And going to the Bible, which is 105, do you recall where in the car you found that?

A.   No, I don't.

Q.   What about the shoulder holster, which is D-104; do you remember?  That's that cloth shoulder holster.

A.   No.  I'm sorry, I don't.

Q.   All right.  You've already talked about 107, which is the box that was in the trunk; correct?

A.   Correct.

Q.   And the metal clipboard which is D-108, you indicated you don't recall where that was found?

A.   I don't recall.

Q.   Now, what about 109, which is the metal ticket book?

A.   I don't recall.

Q.   All right.  You've already said that the money was scattered throughout the car; is that correct?

A.   The change was, yes.

Q.   Do you remember where the five dollar bill was?

A.   No.

Q.   What about the raffle tickets, which are D-111?

A.   No.

Q.   You've already said the portable TV was in the trunk in the box; right?

A.   I don't recall if it was in the -- in the box, but it was in the trunk.

Q.   What about the glasses case, which are D-113?

A.   I don't recall for sure.

Q.   And what about the box with the two cigars?

A.   I don't recall.

Q.   Now, you also said there were two right-handed gloves that you found, there on the sunglasses.  Do you remember where those were?

A.   No.

Q.   You said D-118, which was the coffee mug, was in the trunk; is that correct?

A.   It was in the trunk in the box.

Q.   The two pairs of sunglasses, which are 119 and 120, do you recall where they were?

A.   No.

Q.   Defendant's Exhibit 121, which is the clipboard, the fiberboard clipboard, the brown clipboard, right --

A.   I know it's here.  Oh, yes.

Q.   Do you recall where that was?

A.   No, I don't.

Q.   You've already testified you don't recall where the Crown Royal bag came from; is that correct?

A.   Correct.

Q.   What about the miscellaneous papers and items that are contained in the plastic bag in D-123 and 124?

A.   I don't recall.  I just --

Q.   You said there was a hand mirror, which was Defendant's Exhibit 125.

A.   Yes.

Q.   Do you remember where that was?

A.   No.

Q.   What about the soup packet?

A.   No.

Q.   And what about the envelopes, which are D -- what did we mark all those envelopes -- D-129?  I'm sorry.

A.   No, I don't remember.

Q.   What about the two packs of gum, which are 27 and 28?

A.   No, I don't remember.

Q.   And you say that the evidence tag, which is D-130, was tied to the box.  Was that tied after you conducted your search?

A.   Yes.

Q.   Now, I'd also like to ask you on these items, you Luminoled the entire vehicle; is that correct?

A.   Yes.

Q.   And did you find any evidence of blood other than the indications which have been marked here on the car seat which you've previously identified?

A.   No.

Q.   Did you find any indications or splatter anywhere around on the seat?

A.   No.

Q.   Would that have shown up with Luminol?

A.   It should have, yes.

MR. PORTER:  Your Honor, that's all the state would have.

THE COURT:  All right.  Mr. Moore, what's your argument at this point, and what do you want to say with respect to --

MR. MOORE:  Your Honor, two points.  There's some Polaroid photographs -- let me ask her first where I think they are, if I could.

THE COURT:  Okay.  Go ahead.

     REDIRECT EXAMINATION - JURY OUT

BY MR. MOORE:

Q.   Technician White, were Polaroid photographs taken of all the items in the car before they were removed?

A.   No.  There were some photographs taken, but I believe I had removed most of the personal items.

MR. MOORE:  Mr. Porter, do you have those Polaroids that were taken?

MR. PORTER:  They're down in my office, Mr. Moore.  It will take a minute to get them.

THE COURT:  Let me ask, Mr. Moore, what do you propose to do with these exhibits or -- does this -- are these the exhibits that you want to offer in?

MR. MOORE:  These exhibits, Your Honor, we would offer them for the purpose of showing that the police did not do a thorough investigation, that they did not test these other items, that they tested certain items and did not test others, and there was no reason to test one item and not test another item.  They just arbitrarily chose certain items and tested them, and did not test other items that were equally relevant.

THE COURT:  Mr. Porter?

MR. PORTER:  Your Honor, we argue on two points.  Number one, this witness cannot bring -- this witness cannot bring those items in.  She has no recollection of where the items were; so, therefore, their argument about whether or not it's relevant can't be supported by this witness.

Second of all, the state, through the questioning of Mary Ann White, if the defense theory was true, there would have been indications of blood spatter somewhere else on the seat, and it would have shown up on the Luminol, which would have then made those items relevant.  The only evidence of blood that we have is the one small spot in the entire vehicle, the one small spot on the armrest.

THE COURT:  All right.  Well, I --

MR. PORTER:  And, Your Honor, that goes particularly for the items that were in the trunk.

THE COURT:  Well, I believe they may have some -- I think they may have at least some -- may provide some benefit to the jury, and I think they're at least collaterally relevant, and I'm going to allow them in if you can lay the foundation to put them in.  So I'll allow --

MR. PORTER:  But, Your Honor --

THE COURT:  -- at least I'll allow that line of inquiry.

MR. PORTER:  Is this witness sufficient to lay that foundation?

THE COURT:  Well, she said she got them either from the inside or the trunk, one or the other, and I think that's -- I think that's a matter for the jury to take up what that's worth to them, if anything.  So I'm going to allow you to inquire into it, and you can offer them, and we'll hear any objection at that point.

Anything else, Mr. Moore?

MR. MOORE:  Your Honor, I would like to have a look at those photographs that Mr. Porter sent for.

THE COURT:  Well, is that matter you're entitled to them?  Does Mr. Porter have any objection to producing them?

MR. PORTER:  No.  I have to look at the photographs.  I don't know which one he's referring to.

THE COURT:  Okay.

MR. PORTER:  I have original Polaroid photographs.  The witness has testified.  I can't make my objection until I see what he wants to do.

THE COURT:  Well, I'm inclined at this point, let's proceed on.  Let's take about five minutes, take a short recess, and we'll bring the jury back and you can proceed on with the line of inquiry that you want to, Mr. Moore.

MR. MOORE:  Thank you, Your Honor.

[Break taken]

MR. MOORE:  Mr. Moore, we have -- this is a witness who has testified before.  Are you going to be calling other witnesses that have already been to the stand?

MR. MOORE:  There's going to be a couple of them, Your Honor.

THE COURT:  Okay.  Do you want to re-swear them or not?  I don't really care.  I don't think it makes any difference.

MR. MOORE:  I don't think it makes any difference either, Your Honor.  I just didn't know how the Court wanted me to proceed.  We had somebody re-sworn the other day, so I didn't know if you --

THE COURT:  Yes.  It makes no difference to me.  If you want to re-swear them, that's fine.  All right.  Are you ready?

MR. MOORE:  Yes, Your Honor.  Let me get these marked.

[Defendant's Exhibits 131, 132, 133 and 134 were  marked for identification by the court reporter.]

THE COURT:  All right.  Bring the jury back.

MR. MOORE:  Your Honor, does the Court want me to elicit the foundation testimony again in front of the jury or do you want me to just go ahead and --

THE COURT:  Mr. Porter?

MR. PORTER:  I'm sorry, Your Honor?

MR. MOORE:  My question was do you want me to elicit the foundation testimony again in front of the jury or just go into the items that she found in the car?

MR. PORTER:  Your Honor, we object to the foundation.  We think the foundation's been laid, but we -- given the Court's ruling, I don't think it's going to be necessary to go into the foundation for those items.

THE COURT:  All right.  I think if he repeats those questions and he offers them, they're coming in.

MR. PORTER:  Your Honor, you've already made your ruling and the state has -- I except to that ruling, but I can -- I live with it.

THE COURT:  All right.  What exhibit numbers are those photographs going to be, Mr. Moore?

MR. MOORE:  D-131, 132, 133 and 134, Your Honor.

THE COURT:  All right.  Thank you.

[The jurors were escorted to the courtroom.]

THE COURT:  Proceed when you're ready, Mr. Moore.

     DIRECT EXAMINATION RESUMED - JURY IN

BY MR. MOORE:

Q.   Now, Technician White, have you had occasion -- did you have occasion to search Unit 197, Mike Chapel's car, in 1993?

A.   I inventoried it.

Q.   You inventoried the vehicle?

A.   Yes.

Q.   And in the course of that inventory, did you take possession of certain items?

A.   Yes, I did.

Q.   Looking at Defendant's Exhibit 107 which is a plastic container --

A.   Yes.

Q.   -- did you use Defendant's Exhibit 107 to store those items in?

A.   Yes, I did.

MR. MOORE:  Your Honor, we'd tender Defendant's Exhibit Number 107.

THE COURT:  Mr. Moore -- or Mr. Porter?

MR. PORTER:  Your Honor, the Court's already ruled on that over our objection.

THE COURT:  It's admitted.

MR. MOORE:  Has 106 already been admitted, your Honor?

THE COURT:  No, sir.

BY MR. MOORE:

Q.   I'm going to show you Defendant's Exhibit Number 106 and ask if you can identify those.

A.   It's a pair of fingerless gloves.

Q.   And where did those gloves come from?

A.   Inside Unit 197.

Q.   And was that in 1993 when you took possession of those?

A.   Yes, it was.

Q.   And did you take possession of this property all on the same day?

A.   Yes, I did.

Q.   And do you know approximately what day or month that was?

A.   It was 4/29/93.

MR. MOORE:  Your Honor, we would tender Defendant's Exhibit 106.

THE COURT:  Same objection, Mr. Porter?

MR. PORTER:  Your Honor, we stated our position as to all these items.

THE COURT:  All right.  Do you want to -- we'll go ahead.  Defendant's 106 is admitted.

BY MR. MOORE:

Q.   I'm showing you Defendant's Exhibit Number 105 and ask if you can identify that item.

A.   Yes.  It's a Living Bible that I removed from Unit 197.

Q.   Okay.  And this was on the same date when you retrieved all the other items in 1993?

A.   That's correct.

MR. MOORE:  Your Honor, we'd tender Defendant's Exhibit Number 105, for the record.  We understand it will not go out to the jury.

THE COURT:  All right.  Mr. Porter, anything you wish to add?

MR. PORTER:  No, Your Honor.

THE COURT:  It's admitted.

MR. MOORE:  I believe Defendant's Exhibit Number 103 was previously admitted; is that correct, Your Honor?

MR. PORTER:  That's correct, Your Honor.  It's been admitted without objection.

THE COURT:  And 103 is in.

MR. MOORE:  And Defendant's Exhibit Number 104, which is the gun belt and everything, we would tender that if it hasn't been previously admitted, Your Honor.

THE COURT:  It's been admitted.

BY MR. MOORE:

Q.   I'm going to show you what's been marked as Defendant's Exhibit 109 and ask if you can identify that.

A.   Yes.  This is the metal ticket book holder that I removed from Unit 197.

Q.   Okay.  And that was in April of 1993?

A.   Yes, it was.

MR. MOORE:  We'd tender Defendant's Exhibit 109, Your Honor.

THE COURT:  Anything else, Mr. Porter?

MR. PORTER:  No, Your Honor.

THE COURT:  It's admitted.

BY MR. MOORE:

Q.   I'm going to show you what's been marked as Defendant's Exhibit Number 110 and ask if you can identify that.

A.   This is $6.31 that I removed from Unit 197.

Q.   And was that in April of 1993 that you removed that from Officer Chapel's car?

A.   Yes, it was.

MR. MOORE:  We'd tender Defendant's Exhibit Number 110, Your Honor.

THE COURT:  Anything you wish to add, Mr. Porter?

MR. PORTER:  No, Your Honor.

THE COURT:  110 ten is admitted.

BY MR. MOORE:

Q.   I show you Defendant's Exhibit Number 111 and ask if you can identify that.

A.   This is a book of raffle tickets that I removed from Unit 197.

Q.   Was that in April of 1993 that you removed that?

A.   Yes, it was.

MR. MOORE:  Your Honor, we tender Defendant's Exhibit Number 111.

THE COURT:  Anything else from the state?

MR. PORTER:  No, Your Honor.

THE COURT:  111 is admitted.

BY MR. MOORE:

Q.   I'm going to ask you to look at Defendant's Exhibit Number 112 and ask if you can identify that.

A.   That's the Bentley TV set that I removed from Unit 197.

Q.   Okay.  And was that in April of 1993 that you removed that?

A.   Yes, it was.

MR. MOORE:  Your Honor, we'd tender Defendant's Exhibit 112.

THE COURT:  Anything else from the state?

MR. PORTER:  No, Your Honor.

THE COURT:  112 is admitted.

BY MR. MOORE:

Q.   I'm going to show you what's been marked as Defendant's Exhibit Number 113 and ask if you can identify that.

A.   This is the glasses case that I removed from Unit 197.

Q.   Okay.  And was that in April of 1993 when you removed that April 29th?

A.   Yes, it was.

MR. MOORE:  Your Honor, we'd tender Defendant's Exhibit 113.

THE COURT:  Anything else from the state?

MR. PORTER:  No, Your Honor.

THE COURT:  113 is admitted.

BY MR. MOORE:

Q.   I'm going to show you Defendant's Exhibit Number 114 and ask if you can identify that.

A.   It's a box containing two cigars.

Q.   Okay.  And where did you get that from?

A.   Unit 197.

Q.   And was that in April of 1993 that you took possession of it?

A.   Yes.

MR. MOORE:  Your Honor, we'd tender Defendant's Exhibit 114.

THE COURT:  Anything else from the state?

MR. PORTER:  No, Your Honor.

THE COURT:  114 is admitted.

BY MR. MOORE:

Q.   I'm going to show you Defendant's Exhibit Number 115, which consists of two pieces.  Can you identify that?

A.   It's a cup holder for a vehicle.

Q.   Okay.  And where did that come from?

A.   Unit 197.

Q.   Was that in April of 1993 that you took possession of it?

A.   Yes.

MR. MOORE:  Your Honor, we'd tender Defendant's Exhibit 115.

THE COURT:  Anything else from the state?

MR. PORTER:  No, Your Honor.

THE COURT:  115 is admitted.

BY MR. MOORE:

Q.   I'm going to show you Defendant's Exhibit 116 and ask if you can identify that.

A.   Yes, it's a right-handed glove.

Q.   Okay.  And where did that come from?

A.   Unit 197.

Q.   And was that in April 1993 that you removed that?

A.   Yes, it was.

MR. MOORE:  Okay.  We'd tender Defendant's Exhibit 116, Your Honor.

THE COURT:  Anything else from the state?

MR. PORTER:  No, Your Honor.

THE COURT:  116 is admitted.  Would you approach the bench, please?

[Counsel approached the bench, and the following conference ensued.]

THE COURT:  With these all coming in, if you want to --

MR. MOORE:  Do them collectively.

THE COURT:  -- zip through them and, you know, lump them together as coming from the car.  And you're not going to -- aside from that you're not going to discuss them with her anyway, are you?

MR. MOORE:  Just that they didn't test them or anything.

THE COURT:  Just that that came from --

MR. MOORE:  The car, and as far as she knows they didn't test them.

THE COURT:  As far as putting them in, if you want to lump them together, I don't have a problem.  Mr. Porter, do you have a problem?

MR. PORTER:  I don't have a problem, Your Honor.  As a matter of fact, I think it's somewhat prejudicial to go through them one at a time and make me have a statement that I object to them.

MS. ROGAN:  Uh-huh.

THE COURT:  Yeah.  If you want to offer them together and put them in --

MR. MOORE:  I'll put them together.

THE COURT:  It'll just help expedite things, it seems to me.

MR. MOORE:  Okay.

[Bench conference concluded]

THE COURT:  Go ahead, Mr. Moore.

BY MR. MOORE:

Q.   Technician White, you've had a chance to examine all these items that are exhibited here in front of you?

A.   Yes.

Q.   Okay.  And you've identified each of these items.  I believe we have D-108, D-117, D-129, D-122, D-127, D-126, D-124, D-123, D-125, D-121 and D-128.  Have you had a chance to examine all --

A.   [Indicating]

Q.   Excuse me.  You're right.  Also, D-119 and D-118 and Defendant's Exhibit Number 130.  Have you had a chance to examine each of those items?

A.   Yes, I have.

Q.   And did you remove each of those items from Officer Chapel's car in 1993 when you searched it?

A.   Yes, I did.

Q.   Okay. 

MR. MOORE:  Your Honor, we would tender those items I just went through at this time.

THE COURT:  I believe that's Defendant's 107 through -- sequentially through D-130.

MR. MOORE:  I believe that's correct, Your Honor.  Some of them may have already been admitted, but that's the -- they're included.

THE COURT:  I believe those are the ones that have not been admitted yet. 

All right.  Anything else from the state?

MR. PORTER:  No, Your Honor.

THE COURT:  Defendant's 107 through 130 are admitted.

BY MR. MOORE:

Q.   Now, Technician White, those items that you just examined, D-107 through D-130, which are in the blue plastic container, were any tests run on any of those items, to your knowledge?

A.   No.

Q.   Were you requested to perform any sort of chemical tests, Luminol or anything like that, on any of those items?

A.   No.

Q.   I'm going to show you three photographs, Defendant's Exhibit Number 131, Defendant's Exhibit Number 133 and 134, and ask if you can identify any of those.  If you can identify them, identify them by number.

A.   There's four.

Q.   Was it four?  I'm sorry.

A.   Yeah.  Two of them were stuck together.

Q.   What was the number on the other one?

A.   Sorry, I didn't hear your numbers.  It's 131 through 134.

Q.   Defendant's Exhibits 131 through 134.  Would you examine those and see if you can identify any of them?

A.   I didn't take any of these pictures, and they don't have the unit number written on them.

Q.   So your testimony is you can't identify them; is that correct?

A.   That's correct.

MR. MOORE:  Your Honor, I believe we've previously tendered Defendant's Exhibit 101, which is a bag of miscellaneous papers.

THE COURT:  I show it as being identified in some manner, but I don't show it being offered or admitted.

MR. MOORE:  We would offer it.

THE COURT:  And I'm not sure -- I'm not sure it was identified by the witness.

MR. MOORE:  I'll ask her again.

BY MR. MOORE:

Q.   Defendant's Exhibit 101, could you identify that for us, Technician White?

A.   These are miscellaneous papers that I removed from Unit 197.  This is my handwriting on the back.

Q.   Did you remove those in April 29th of 1993?

A.   Yes.

Q.   And how do you know that?

A.   Because that was the night that I did everything to his car.

Q.   But is there anything on that exhibit that allows you to identify it?  Is there any markings or anything you've placed on it?

A.   No.  I mean I have the date on here that I put it into the property room, and I have the case number, and I have where I collected it from.

Q.   Okay.  Is that how you identify the writing on it?

A.   Yes.

MR. MOORE:  We would tender Defendant's Exhibit 101 at this time, Your Honor.

MR. PORTER:  Your Honor, the agreement of the state in the stipulation was that those were authentic documents, but I have not reviewed each individual document.  There are blank reports, there are blank pieces of paper, there are pay stubs from the defendant, there's any number of miscellaneous personal papers which may --

THE COURT:  Issue of relevance, is that what you're saying?

MR. PORTER:  There's an issue of relevance, and there's a significant issue of hearsay in regard to the contents of the documents.

THE COURT:  Okay.

MR. MOORE:  Your Honor, if any individual documents are going to be gone into and have testimony about them or going out with the jury, I will state to the Court I will take them out and have them individually marked and allow the Court to make a ruling at that time whether or not the individual documents --

THE COURT:  Okay.  You're offering -- you're offering Defendant's 101 at this point for the record only?

MR. MOORE:  Yes, sir.

THE COURT:  Mr. Porter?

MR. PORTER:  Well, Your Honor, even for the record, I have no objection with the procedure described by Mr. Moore that the documents themselves -- and I've stipulated that it is authentic, but I don't think it needs to be admitted.  It can be drawn from as long as it's been properly identified.

THE COURT:  I'm inclined to agree, Mr. Moore.  It's refused at this point.

MR. MOORE:  Okay.  No further questions of this witness, Your Honor.

     CROSS EXAMINATION

BY MR. PORTER:

Q.   Ms. White, I want to talk about some of the items that were removed from the vehicle, and I'm going to refer to them by the same defendant's exhibit numbers.  When we talk about the pursuit pack, you've already stated that it fits on the car seat like that, and is that where you removed it from?

A.   Yes.

Q.   The doll or the figurine?

A.   Yes.

Q.   You don't recall where you removed that from, do you?

A.   No.

Q.   And the shoulder holster, do you remember where you took that from?

A.   No.  No.

Q.   What about the Bible?  Do you remember where that was from?

A.   No.

Q.   And the mesh gloves, do you remember where that was from?

A.   No.

Q.   So they could have been anywhere in the car?

A.   That's right.

Q.   And I believe you testified outside the presence of the jury that the box itself, the blue box, came out of the trunk; is that right?

A.   Yes, it did.

Q.   And what about the big metal clipboard?  Do you know where that came from?

A.   No.

Q.   And the metal ticket book?

A.   No.

Q.   What about the $6.30 in the -- with the five dollar bill and various change?

A.   No.

Q.   You also described Defendant's Exhibit Number 111 as the raffle tickets.  Do you know where that came from in the car?

A.   No.

Q.   And 112, which is the portable TV, I believe you said that came from the trunk; is that right?

A.   Yes.

Q.   And the glasses case, D-113, do you know where that came from?

A.   No.

Q.   And the box with the two cigars, do you remember where that came from?

A.   No.

Q.   The -- let me just list them out.  The cup holder, do you remember where that came from?

A.   No.

Q.   The two right-handed gloves?

A.   No.

Q.   The coffee mug?

A.   It was in the trunk.

Q.   Do you remember the two pairs of sunglasses, where they came from?

A.   No.

Q.   The clipboard?

A.   No.

Q.   The Crown Royal bag?

A.   No.

Q.   Do you remember where the miscellaneous items and papers that were contained in the plastic bag were from?

A.   No.

Q.   What about the hand mirror?

A.   No.

Q.   And what about the packet of soup?

A.   No.

Q.   What about the two packages of gum?

A.   No.

Q.   And the brown envelope, do you remember where that came from?

A.   No.

Q.   And then D-130 was an evidence tag that you tied to the box once you collected all this stuff up; right?

A.   That's correct.

Q.   Now, let me ask you, you testified earlier that you Luminoled the entire vehicle of the car -- the entire interior of the vehicle; is that right?

A.   That's right.

Q.   And the only spot that indicated blood was right here; right?

A.   That's correct.

Q.   Was there any blood anywhere indicated by the Luminol test anywhere else on the seat?

A.   There was a glowing on the back, just adjacent to the armrest.

Q.   Right here? 

A.   Yes, coming down, and then on the armrest.

Q.   All right.  So it was right here?

A.   Right.

Q.   Okay.  Now, when you do a Luminol test, do you begin with the lowest level of the substance and then work your way through whatever may have been piled on it, or do you just do it as it is?

A.   [No response]

Q.   Well, let me rephrase my question.  Was there anything about -- was there anything about or there wasn't anything about what you saw in the results of your Luminol that would have indicated that any blood got on anything that you've testified to here today, was there?

A.   No.

Q.   And if there had been anything that indicated that blood had gotten anywhere else in that patrol car, you would have Luminoled it, wouldn't you?

A.   Yes.

Q.   So all of this stuff that was taken out of the car, was it in police custody when you took it?

A.   Yes.

Q.   And it was taken the same night you did the Luminol; right?

A.   That's correct.

Q.   And if you had done the Luminol and said, 'Gee, it looks like there's the outline of a clipboard here,' wouldn't you have thought maybe some of the blood went on the clipboard?

A.   Yes, of course.

Q.   And wouldn't you have Luminoled the clipboard if you had seen what I just described?

A.   Yes.

Q.   So -- and you didn't do any of that, did you?

A.   No.

Q.   Now, all of this stuff was eventually returned to the defendant, wasn't it?

A.   Yes.

Q.   And it's been in his custody?

A.   That's correct.

Q.   And do you have any idea -- can you look at it and see if there's any indication of any scientific tests that have been done on it?  Does it look like it's been sprayed with Luminol, based on your examination?

A.   No.

Q.   Now, you can buy Luminol almost anywhere, can't you, from the proper chemical houses?

A.   Yes.

Q.   It's not a secret chemical that's hidden away, is it?

A.   Not to my knowledge.

Q.   And, as a matter of fact, the Gwinnett County police buy it in big barrels, don't they?

A.   Well, we buy it in bottles.

Q.   Yes.  So it's not hard to find?

A.   No.

MR. PORTER:  Thank you.  That's all the questions I have.

THE COURT:  Redirect?

     REDIRECT EXAMINATION

BY MR. MOORE:

Q.   Yes, ma'am.  Technician White, Mr. Porter asked you about did you see any blood anywhere.  Did you see any blood anywhere in that vehicle when you first went and looked at it?

A.   No, I didn't.

Q.   Wasn't that the reason for using the Luminol?

A.   Yes.

Q.   Because you can't see blood a lot of times; it's not visible?

A.   Right.

 [Defendant's Exhibits 135 and 136 were marked for identification by the court reporter.]

BY MR. MOORE:

Q.   I'm going to show you what's been marked as Defendant's Exhibit Number 135 and 136 and ask if you can identify those.

A.   This is a photograph of --

Q.   Would you identify it by number so we know which one you're talking about?

A.   Oh, I'm sorry.  Defendant's Number 136 is a photograph of the pursuit pack, and 135 is a photograph of the inside of the trunk.

Q.   And do you know who took those photographs?

A.   I did.

Q.   And are both those photographs, Number 135 and 136, are they a true and accurate representation of the scene that they depict?

A.   Yes.  The pursuit pack had been removed from the vehicle.

Q.   And were those taken in December -- I mean, excuse me, in April of 1993?

A.   Yes, they were.

Q.   Was that at the time that you conducted the search where you removed all these other items?

A.   Yes.

Q.   And Mr. Porter asked if you'd Luminoled the entire car, and I don't recall, did you Luminol the trunk?

A.   No.

Q.   Did you Luminol the back seat of the car?

A.   No, I didn't.

Q.   Okay.  And did you Luminol the pursuit pack, which was on the seat right beside where you did find blood?

A.   No.

MR. MOORE:  I would tender Defendant's Exhibits 136 and 135, Your Honor.

THE COURT:  Mr. Porter?

MR. PORTER:  No objection, Your Honor.  The foundation's been laid.

THE COURT:  Defendant's 135 and 136 admitted without objection.  Go ahead, please.

BY MR. MOORE:

Q.   I'm going to show you Defendant's Exhibit Number 135 again.  That's a photograph of the trunk of the car?

A.   Yes.

Q.   And it shows the container, the blue container.  It's that plastic container that's here on the floor of the courtroom, isn't it?

A.   Yes, it does.

Q.   Okay.  Had the TV set already been removed at that point or do you know?

A.   I don't believe it had.  It doesn't show the entire trunk.  I don't remember.  I don't think it was in this box.  I think it was laying on the floor of the trunk, if I recall correctly.  I'm not --

Q.   Okay.  I'm going to show you D-136 and ask -- that's the photograph that you identified as being the pursuit pack?

A.   Yes.

Q.   Is that the same pursuit pack that's here in the courtroom?

A.   It appears to be, yes.

Q.   And does it have anything additional that this one doesn't have?

A.   It looks like it has a billy club.

Q.   A billy club or a night stick?

A.   Yes.

Q.   Now, the night stick that was in that photograph, was it with the pursuit pack when you photographed it?

A.   Yes.

Q.   Okay.  And was it tested in any way, the night stick?

A.   No.

Q.   Does the night stick that's in the pursuit pack, did you put that on the inventory sheets anywhere?

A.   It's not listed on these.  These are only the personal items.

MR. MOORE:  No further questions, Your Honor.

THE COURT:  Recross?

MR. PORTER:  I have no other questions for Technician White, Your Honor.

THE COURT:  You can come down.  Call your next witness, please.

[The witness stepped down from the stand.]

MR. MOORE:  We'd call Sergeant D. E. Stone.

THE COURT:  Sergeant Stone, if you'll take the stand up here.  Mr. Moore, if you'll readminister the oath.

[The witness stepped to the stand.]

MR. MOORE:  If you'll hold up your right hand, please.  Do you solemnly swear the testimony you're about to give in this case will be the truth, the whole truth, and nothing but the truth, so help you God?

THE WITNESS:  I do.

Whereupon,

     SERGEANT DONALD E. STONE

having been recalled as a witness and duly sworn, was     further examined and testified as follows:

     DIRECT EXAMINATION

BY MR. MOORE:

Q.   State your name, please.

A.   Donald E. Stone.

Q.   Okay.  Sergeant Stone, how long have you been a Gwinnett County police officer?

A.   Twenty-one years.

Q.   And how long have you worked in the Buford area or Buford precinct, the northside precinct it is now?

A.   Approximately eighteen years.

Q.   Now, during the eighteen years that you've been a police officer, how long have you -- are you Mike Chapel's -- were you Mike Chapel's supervisor?

A.   Yes.

Q.   Okay.  And how long were you his supervisor?

A.   The majority of the time he's been here.  He worked at other precincts when he first arrived, went through the academy, made his rounds through the other precincts, then transferred to Buford, and since he's in Buford I was his supervisor most of the time there.

Q.   And did you get to know Mike Chapel?

A.   Yes.

Q.   And how well did you get to know him?

A.   I was good friends with him, yes.

Q.   Now, during the time that he worked for you as a police officer, how would you evaluate Mike Chapel's abilities as a police officer?

A.   I would give him --

MR. PORTER:  Your Honor, I'm going to object to this.  This is in the form of good character reference, and there is a statutory method of introducing evidence of good character, which is required by law, and is of a limited value.  To go into Officer Michael Chapel's evaluation as a police officer is, in effect, good character evidence through the incidents of specific good acts, which is forbidden by law.

THE COURT:  Mr. Moore?

MR. MOORE:  Your Honor, we believe Mr. Porter's opened it up because he's gone into the fact -- he made a big deal out of the fact that he may have violated procedures by not turning in reports, not doing various police procedures that were supposed to be done, that he didn't follow them, and we believe we're entitled to go into with his supervisor as to whether or not he, in fact, did follow police procedures.

MR. PORTER:  Your Honor, that is relevant to the issue of motive and intent to commit the crime, and as long as cross-examination is limited to that, but here we have an attempt that was done earlier through cross-examination of this witness, and now through the direct of this witness to introduce evidence of good character.

THE COURT:  The objection is sustained to the questions as posed, Mr. Moore.

BY MR. MOORE:

Q.   Over the years, did Officer Chapel ever fail to turn in any reports?

A.   Not that I'm aware of.  He would hold some reports till the next day gathering information, but far as I know he's always turned in reports.

Q.   Did you ever have to remind him?

A.   Not that I recall.

Q.   Now, in this particular case, when did Officer Chapel first tell you about going to Ms. Thompson's?

A.   The day that he received the call to go to her house on the burglary.

Q.   And did you discuss it with him?

A.   Yes.

Q.   And do you recall what he told you?

A.   Yes.

Q.   And what did he tell you?

A.   He told me that the -- he didn't believe it was a real burglary, that it was probably an inside job, that burglars don't operate going in and taking money from a residence and leaving significant amounts of money still at the scene.

Q.   And did you give him any advice?

A.   I told him he should write a report.  He said he would wait -- would like to wait and see if Ms. Thompson could gather some more information from her son since he said -- Chapel told me that there's only two people that knew where the money was hidden, and it was Ms. Thompson and the son, and he was going to -- she was going to talk to him and see if she could get more information.

Q.   Do you know whether or not he talked to anyone else about it?

A.   That Officer Chapel talked to anyone else?

Q.   Yes, sir, in your presence.

A.   Not in my presence, no.

Q.   Did anyone else mention to you that he'd been out there?

MR. PORTER:  Your Honor, that would be hearsay.  We would object.

MR. MOORE:  Your Honor, I'm not asking what they said.  I'm asking if they -- anybody said something to him.

THE COURT:  Objection's overruled.  Go ahead, please.

BY MR. MOORE:

A.   [Continuing]  Not that I'm aware of.

Q.   Now, tell the jury what a Code 32 is.

A.   Code 32 is a code the department uses for when a victim calls for an incident and they don't want a report.  It's stated on the -- on our log sheets, 'No report requested.'

Q.   Is it uncommon to have a Code 32?

A.   No, not at all.

Q.   In your opinion, based on what Mike Chapel told you, was a Code 32 appropriate in this case?

A.   It could be.  Gathering -- the necessity to have more information, it could be.

Q.   Did you -- did you suggest or did you order Mike Chapel to write a report.

A.   I suggested he write a report.

Q.   Okay.  So that wasn't ordered?

A.   No.

Q.   There's an item laying there on the table in front of you, Defendant's Exhibit Number 76.  Have you ever seen an item like that?

A.   Not that I recall.

Q.   Do you know whether or not Mike Chapel had an item like that to carry his keys in?

A.   Not that I'm aware of.  He had several different key rings.  That could possibly be one of his key rings.

Q.   I'm going to show you what's been marked as Defendant's Exhibit Number 103 and ask if you can identify that.

A.   This is a figurine that Officer Chapel sometimes carried on the dash of his patrol car.

Q.   Was there a name for it?

A.   I believe it's called the Terminator.

Q.   And it's got some Velcro or something on the bottom.  How was it on his dash of his car?  How would it be carried on the dash of his car?

A.   It would be carried if -- a piece of Velcro would be across the top and it would be stuck down like this.

Q.   And where on the dash would it be?

A.   As I recall, it would be somewhere in the center of the dash.

Q.   Was it visible from outside the car?

A.   Yes.

Q.   Was it visible from the side if you looked in the side window of the car?

A.   It could be, yes.

Q.   I'm going to show you what's been marked as Defendant's Exhibit Number 106 and ask you if you've ever seen anything like that.

A.   These are gloves that appear to be the style and nature that Officer Chapel sometimes wore.

Q.   Okay.  When did you -- how many times did you see him wearing gloves like that?

A.   Numerous times.

Q.   Were there any occasions in particular when he wore gloves like that?

A.   No, not in particular.

Q.   Were there any weather conditions or anything that he would wear gloves like that?

A.   If it was cold he would wear gloves, yes.

Q.   Any other weather conditions that he would wear them in you ever saw him wear them?

A.   Probably when it was raining.

Q.   Do you know why an officer would wear gloves like that when it was raining?

A.   It would probably help him on his grip.

Q.   Okay.  And why would that be important?

A.   If he had to secure someone and he wouldn't slip away from him, he'd need all grip power that would be necessary for him to --

Q.   And if he had to use a weapon, would that be -- could that be a reason for the gloves?

A.   Yes.  If he was using a metal flashlight, that would probably keep the flashlight from slipping out of your hands.

Q.   Was Mike Chapel good friends with Officer Reddy?

A.   Yes.

Q.   Did he talk to him about the things that went on on the shift just like he did you?

A.   Yes, he did.

Q.   Do you know whether or not he talked to Officer Reddy about the call at Ms. Thompson's house?

A.   No, I do not.

Q.   Who all worked on the shift that you and Mike Chapel worked on?

A.   I'd have to see a roster to remember them all exactly, but they would be Reddy --

Q.   I'm talking about 1993, too.  I'm not talking about 1995.

A.   Yeah.  Yeah.  It would be Officer Reddy at that time, Officer Yonker, Officer Martin, Officer Geidner, I believe.  That's all I can recall right off the top of my head without seeing a roster.

Q.   Now, Officer Chapel's car was Unit 197, back in 1993?

A.   His new patrol car, yes.

Q.   That was his patrol car; right?

A.   Yes.

Q.   Do you recall if there was anything unusual or unique about the dome light in his car?

A.   No, I don't recall for sure.

Q.   You don't know what color the lens was that was in the dome light?

A.   When it's issued to him it's -- it's white or off-white color.

Q.   Did the officers sometimes change it?

A.   They sometimes do, yes.

Q.   And why do they change it?

A.   To cut down the glow in the car.

Q.   Okay.  What color would they change them to?

A.   Most of them would change them to red.  That's been my experience.

Q.   And do you know whether or not Mike Chapel's car had been changed to red?

A.   I don't recall if it's red or not.

Q.   Now, on the night of April the 15th, 1993, what was weather like that night?

A.   April the 15th it was a thunderstorm, lighting and rain.  We had tornado warnings issued by the National Weather Service that night.

Q.   And what time did the weather start getting bad that night?

A.   Just before dark.  I'd say around 8:30.

Q.   And where were you when the weather started getting bad?

A.   I was on Main Street in downtown Buford at the Methodist Church.

Q.   Was anyone else there present with you?

A.   Officer Chapel and Officer Reddy.

Q.   And did y'all have a discussion about whether you were going to continue patrolling or what you were going to do?

A.   As the weather started getting bad, the National Weather Service broke in on the radio and stated the warnings.  I told Officer Chapel and Reddy I was going to the fire station and watch the thunderstorms move on the radar.

Q.   Was anybody wearing their rain gear equipment at that time?

A.   Not when we went to the fire station, I don't believe, because it wasn't raining exactly then.

Q.   At the church, back at the church, was anybody wearing rain gear then?

A.   No, I don't think so.

Q.   Now, what kind of rain gear did you have and what kind did Officer Reddy have?

A.   I have a -- it's yellow with a police mark on the back, police lettering.

Q.   Is it a full-length raincoat or is it a jacket?

A.   It's -- it's a jacket, probably three-quarter, goes just below the waistline.  It would cover up your weapon.

Q.   And what kind of rain gear did Officer Reddy have at that time?

A.   If he was issued one, that would be the same kind he had.

Q.   In other words, everybody was issued the same type of raincoat?

A.   Yes, sir.

Q.   I'm going to show you what's been marked as Defendant's Exhibit Number -- excuse me, State's Exhibit Number --

MR. MOORE:  Is it 129, Mr. Porter?

MR. PORTER:  129 is the right number.

BY MR. MOORE:

Q.   -- State's Exhibit Number 129.

A.   That's the same jacket that's issued by the police department.

Q.   And that's the standard issue that everybody has?

A.   Yes.

Q.   Is there anything unique about Officer Chapel's?

A.   It has the badge pinned to the outside.  That was his -- his style of putting his badge on the outside.

Q.   But other than the badge, is there anything unique about his coat?

A.   No, other than size.

Q.   And Officer Reddy would wear about the same size coat, wouldn't he?

A.   Yes.

Q.   Now, after you left the church, what did you and the other officers do?

A.   We went to the fire station.

Q.   And what did you do at the fire station?

A.   We watched the weather on the TV.

Q.   Was there a movie or anything on?

A.   I don't recall one, but there probably was when we arrived.

MR. MOORE:  Your Honor, at this time, Defendant's Exhibit Number 137, which is a certified copy of  microfilm of TV listings from the Atlanta Constitution and weather statistics from local climatological data housed in the Lawrenceville branch of the library here in Lawrenceville, Georgia, and they're certified by Ms. Kathy Crone, and we would tender that into evidence at this time.

MR. PORTER:  Your Honor, we would stipulate that those are official documents within the -- within the custody of the library and we stipulate to their admission.

THE COURT:  All right.  Defendant's 135 is admitted without objection.

MR. MOORE:  It's 137, Your Honor.

THE COURT:  137, yes.  Thank you.

BY MR. MOORE:

Q.   I'm going to show you what's been marked as Defendant's Exhibit Number 137 and ask if you can look at those TV listings and see if that refreshes your memory.

A.   No, sir.  At that time -- at the time that's stated here, it doesn't bring back anything.

Q.   Okay.  So you still don't remember it?

A.   No.

Q.   Okay.  Now, did you have the occasion on the subsequent nights of April 15th, 16th and perhaps the 17th to participate in road checks up at Gwinnco Muffler Shop?

A.   Yes.

Q.   Who all was participating in those?

A.   There were several of the traffic cars.  Lieutenant Latty, myself, Officer Chapel was there.  It seems like there was four or five traffic cars.  I wouldn't remember exactly who they was.

Q.   Who was stopping the motorists and talking to them?

A.   All of the officers there were stopping them.

Q.   Were the people stopping them in uniform?

A.   Yes.

Q.   And where were the detectives?

A.   They was parked in the driveway away from the road.

Q.   And how far away from the road were they?

A.   I'd say 20 or 30 feet, probably.

Q.   Can I get you to come down from the stand for a minute?

A.   [Witness complies]

Q.   This is State's Exhibit Number -- is there a number in the corner there?

A.   Two.

Q.   State's Exhibit Number 2, which has been admitted into evidence.  It's a drawing of the Gwinnco Muffler Shop.  And the vehicle here is magnetized.  Would you place the vehicle where the detective vehicle was parked?

A.   I would say it was parked probably in this area right here.  The traffic was being stopped up in here, in an area, say, below this intersection of the driveway, down here.  The officers were stationed back and forth, north and southbound.

Q.   Thank you.

A.   [Witness returns to stand]

Q.   Did you know where Ms. Thompson's car was parked at when she -- when her body was found?

A.   No.

Q.   Now, in April of 1993, is there any kind of hunting season open that time of year?

A.   It might be turkey season.

Q.   Did you and Officer Chapel ever discuss turkey season and going turkey hunting?

A.   Yes.

Q.   And do you recall when you were making business checks or checking for stolen property, did you ever look at anything related to turkey hunting?

A.   Yes.

Q.   What did you look at?

A.   We looked for signs.

Q.   Was Officer Chapel looking for any kind of gun for turkey hunting?

A.   Not that I'm aware of.

Q.   Now, up at the precinct there, there's been testimony that Officer Chapel -- one of his lockers was locked.  Do most of the officers lock their property?

A.   Most of them do, yes.

Q.   Okay.  And why do they lock their property up?

A.   If they have uniforms, most of the time you change clothes and uniforms in there, and you'd want to keep your uniform secure.

Q.   Okay.  And is there anybody that cleans up or works in the precinct there that you'd have reason to believe might take clothes or anything?

A.   The inmates clean the precincts.

Q.   Would that be the trustees?

A.   Yes.

Q.   Those are inmates that are allowed to work at the police station cleanup?

A.   Yes.

Q.   And if there are clothes in there, why would the police department be concerned if they got hold of clothes?

A.   They might could use -- possibly use them for a change of clothes and maybe escape, possibly.

Q.   Okay.  So as a supervisor, you approved of keeping those lockers locked?

A.   It would be my practice.  I kept mine locked, yes. Q.   Do you know what the term 'running the boo' means?

A.   That would be a bluff on somebody.

Q.   And have you ever observed Mike Chapel do that kind of thing?

A.   Yes.

Q.   How many times?

A.   Numerous times.

Q.   Was that a standard practice of his?

A.   Yes.

Q.   Was he successful at it?

A.   Most of the time, yes.

Q.   Now, in your duties as a police officer, have you ever had occasion to have an injured deer or dog that's been hit by a car and you had to put them down?

A.   Yes, many times.

Q.   And how did you do that?

A.   We used the service weapon, or sometimes they'd use a shotgun if they wasn't proficient enough with their revolver.

Q.   Was that for the purpose of putting the animal out of misery?

A.   Yes.

Q.   And when you used a revolver, how would you do that?

A.   We would find the spot on the deer that we're sure would kill it and go for that spot.

Q.   Okay.  Would you get close to them to do it?

A.   Yes.

Q.   And why would you get close?

A.   To make sure you wouldn't have a ricochet from the round.

Q.   Could you come down and demonstrate, maybe, to show the jury how you would have done that?

A.   [Witness complies]

Q.   Assume that like this box here was a dead animal and you were going to -- it had been injured seriously and you were going to put it down.  How would you go about it with a revolver?

A.   Okay.  If this was a deer on the side of the road and it was down, I'd walk up just behind the neck, walk up like that and fire.  [Demonstrating]

Q.   Okay.  Thank you.  You can go back up.

A.   [Witness complies]

Q.   Do you know whether or not Officer Reddy ever had to do that?

A.   Not that I recall.

Q.   Okay.  You didn't personally see it?

A.   No.

Q.   Would it have been unusual for something like that to happen?

A.   No.

Q.   Are there a lot of deer in Gwinnett County?

A.   There are many deer in Gwinnett County.

Q.   Okay.  How frequently do they get hit by cars at night?

A.   Sometimes it can be nightly, two or three calls a night.  It depends on the weather and the time of day.

Q.   Do you hunt deer?  Do you know about deer?

A.   Yes.

Q.   Okay.  What time of day or night do deer come out and usually move around?

A.   Usually at night.

Q.   Now, going back to the fire station there, do you know what time Officer Reddy left the fire station?

A.   I would -- as I recall, it was probably around quarter till ten.

Q.   Sergeant Stone, I'm going to show you what's been marked as Defendant's Exhibit Number 138 and, first of all, without saying what's in it, can you identify what that sheet is?

A.   It's probably some type of printout.

Q.   Drawing your attention to -- in particular to this, would you look at that and see if that refreshes your memory regarding any phone calls?

A.   Yes.

Q.   And did you make a phone call on April the 15th, 1993?

A.   Yes.

Q.   And what time was that phone call made?

A.   I believe it's -- it says 22:17.

Q.   That would be 10:17?

A.   Yes.

Q.   Okay.  And who did you call?

A.   I called my wife.

Q.   Was that your routine, to call your wife before you leave for home?

A.   If -- not on a routine basis, but being in the weather that night, I did call home.

Q.   And how long before you called your wife did Officer Chapel leave the fire station?

A.   As I recall, he left sometime between twenty after and 9:30.

Q.   But how long -- when you made the phone call, working back, how long was it -- from the time he left to the time you made the phone call, how much time elapsed?

A.   You lost me there.  I didn't understand.

Q.   From the time he left until you called your wife, how much time elapsed?

A.   I would say about 45 minutes.

Q.   Do you recall the conversation on Tuesday, April the 20th, 1993, with Captain R. L. Davis?

MR. PORTER:  Your Honor, I'm going to object to this.  This is cumulative.  Mr. Moore questioned Sergeant Stone about this on cross-examination.  It's cumulative of his previous testimony, which is not appropriate for recall of a witness.

THE COURT:  Mr. Moore?

MR. MOORE:  Your Honor, I questioned him regarding a statement that was made to -- that was made to Chief Carl White, but I don't recall questioning about the conversation with Captain Davis.

MR. PORTER:  Your Honor, Mr. Moore brought that out through the testimony of Captain Davis, also, and that would also make it cumulative, and that's not the purpose of the recall of a witness.

THE COURT:  Mr. Moore?

MR. MOORE:  Your Honor, I believe I'm entitled to ask this officer, since he was a party to that conversation with Davis, what his recollection of it is.

THE COURT:  Would you approach the bench, please?

[Counsel approached the bench, and the following conference ensued.]

THE COURT:  I don't recall this document, and I don't know what you're going to ask him.  What is this document?

MR. MOORE:  It's a -- Captain Davis talked to Mike Chapel, and the state brought out that he thought it was unusual and might have said something to the effect, 'I've got an alibi.'  And then I went into, on cross, to the fact that he also talked to Sergeant Stone about what time he left, and he noted the time because he said it was -- he thought it was important at the time.

THE COURT:  Captain Davis's statement.

MR. PORTER:  Captain Davis.

MR. MOORE:  It's Davis, but I want to ask him what his recollection of it is and use that document to refresh his memory.

THE COURT:  Well, was he present?  What was -- what's Stone's connection with Davis?

MR. MOORE:  Stone was talking to Davis.  That's the one that Davis wrote it down in his records.  He recorded what his conversation with Sergeant Stone was.

THE COURT:  With Stone.

MR. PORTER:  But Davis's document can't -- he can ask him about the conversation, but he can't refresh the collection of this witness with Davis's document.

MR. MOORE:  Your Honor, I think you can show a witness any document to refresh a memory.  They didn't have to make it themselves.

MR. PORTER:  It's got to be the witness's own document.  And, Your Honor, this is also cumulative.  This is evidence that Mr. Moore brought out through the testimony of Davis.

THE COURT:  Well, it may be cumulative, but I don't -- I'm not going to keep it out because it may be cumulative or it may have been -- I won't keep it out on that basis.  What is it you want to do with this witness?  What do you want to do?

MR. MOORE:  I want to ask him about whether or not he remembers the time that he told Captain Davis.

THE COURT:  Okay.

MR. PORTER:  Well, I think he can ask that.

THE COURT:  Yeah, I agree.  But I think if -- I think if you show him the document and he says, 'well, this is what Officer Davis said, ' is this the truth -- you know, I --

MR. MOORE:  No.  I'm not going to do that.  I'm going to ask him if his memory is refreshed by it and if he remembers it after seeing the document.

MR. PORTER:  That's what we object to, Your Honor.

THE COURT:  Well, it seems to me that's tantamount to having a transcript, somebody else's transcript or something, and saying, 'Well, here's what somebody else said.  Does this refresh your memory?'  Is that permissible?

MR. MOORE:  Your Honor, I think I could use any document to see if it would refresh a person's memory.  I'm not going to ask him to read it.  I'm not going to ask him to say what's in it.  If he says, 'No, it doesn't refresh my memory,' I think that ends it.

THE COURT:  I'll allow it.  Go ahead.

[Bench conference concluded]

THE COURT:  Go ahead, please.

BY MR. MOORE:

Q.   Sergeant Stone, do you remember a conversation with Captain Davis on April the 20th, 1993, where you talked about Mike Chapel?

A.   I've talked with Captain Davis many times.  Specific dates and times, I don't recall that.

Q.   I'm going to show you what's been marked as Defendant's one hundred and -- don't read it out loud, and don't say what's in it, but see if that refreshes your memory.

A.   [Reading document]  I remember -- vaguely remember this, yes.

THE COURT:  What's your question, Mr. Moore?

BY MR. MOORE:

Q.   And do you remember what time you told Captain Davis that Mike Chapel was at the fire station?

A.   No, I don't.

Q.   You would agree that your memory was fresher then of events than it is now?

A.   That's correct, yes.

Q.   And that whatever Captain Davis, if he testified --

MR. PORTER:  Your Honor, I'm going to object to this.  This witness cannot comment on what another witness's testimony is.

MR. MOORE:  I'll withdraw that, Your Honor.

BY MR. MOORE:

Q.   Now, on the same night, April 15, 1993, did you and Officer Chapel get a call to the Sugar Hill city marshal's office?

A.   On April the 15th?

Q.   Yes, sir, the night of the bad weather.

A.   Sugar Hill city -- not that I'm aware of.

Q.   There wasn't an alarm there that you went out on a call?

A.   The city hall was alarmed.  I just don't remember going to the call, an alarm there.

Q.   You do remember the alarm going off, though, at city hall that night?

A.   Not -- no, I don't remember -- I knew that -- the building is alarmed.  I'd have to see log sheets to answer that, if there was one there that particular night.

Q.   Now, do you know what Mike Chapel's routine was every night about -- around ten o'clock?

A.   Around ten o'clock, he'd usually go and check his gym, make sure it was locked up.

Q.   Okay.  And where is that gym located at?

A.   It's Moreno Street and Garnett Street in Buford.

Q.   Officer Stone, if I could get you to come down again.

A.   [Witness complies]

Q.   I've got a map here I want to get you to -- if you would, take a look and get yourself oriented.  Here's Peachtree Industrial Boulevard.

A.   Okay. 

Q.   Okay.  Could you show the jury where the gym was located?

A.   Here is Georgia 13, also known as Buford Highway.  Here's south Lee Street going north into town.  We have Lee Street here.  Starting right here is Moreno Street.  Traveling -- I guess it would be northbound through town, his gym would be in this area right -- right here, I believe.

Q.   And where is that in relation to --

A.   Basically, here's Garnett Street.  It would be between Garnett Street and Harris Street, right in this area here.

Q.   And where would that be in relation to the precinct, the northside precinct?

A.   The precinct is --

THE COURT:  Sergeant Stone, I think the jurors are having trouble hearing.

MR. MOORE:  Let me see if I can get a pointer here, maybe.

THE COURT:  But I think the jurors are having trouble hearing your voice.  You have a soft voice.  If you'd make an effort to speak up, please, so all the jurors can hear you.

MR. MOORE:  It will make it a little easier if you stand to one side where the jury can see it.

THE WITNESS:  The trouble is I can't see it that far away.

MR. MOORE:  I have that problem, too.

BY MR. MOORE:

A.   [Continuing]  So here's Lee Street.  Going up Lee Street, the gym would be in this area right here, from Garnett Street and Harris Street, right there in that area there.  And the precinct would be in this area right here, Georgia 20 and then 13.  It would be right in this area here.

Q.   How far away is that in distance, in miles, approximately?

A.   I'd say approximately a mile and a half, two miles.

Q.   Thank you.

A.   [The witness returns to the stand]

Q.   How long have you lived in the -- where do you live at, Officer Reddy [sic]?

A.   I live in Cumming, Forsyth County.

Q.   Okay.  And how far away is that from Buford?

A.   That's approximately 22 miles.

Q.   And how long have you lived in that area?

A.   All my life.

Q.   And how old are you?

A.   Forty-six.

Q.   Are you familiar with the Buford area up there when the Bona Allen plant was operating?

A.   Yes.

Q.   And when did the Buford community start to grow a lot?

A.   Probably about seven years ago.

Q.   And what was the Buford community like back in -- when you were growing up back in the forties and fifties, or fifties and sixties, whenever that was?

A.   I would say it was a mill type town.

Q.   And do you mean by mill type town that most people worked at the Bona Allen plant?

A.   As I recall, they did, yes.

Q.   Were there a lot of people moving in and out?

A.   There wouldn't be not at that time.  I wouldn't think so.

Q.   Did most of the people who lived there live there for a long time?

A.   Yes, they tend to be -- do so.

Q.   I'm sorry?

A.   They tend to do so, live in that same area.

Q.   Did children tend to stay there or did they tend to move away?

A.   It would be my opinion that they stayed in town.

Q.   So was that a closed type community?

A.   Yes, it was.

MR. MOORE:  That's all the questions I have for Sergeant Stone.

THE COURT:  Mr. Porter?

     CROSS EXAMINATION

BY MR. PORTER:

Q.   Sergeant Stone, let's talk about the figurine that was on the car that you previously identified as the Terminator.  Didn't the defendant often wear sunglasses and cut his hair to sort of look like the figurine?

A.   Yes.

Q.   And with his size, didn't he sort of look like the same thing as in the movie 'The Terminator'?

A.   I think so, yes.

Q.   What was the Terminator in the movie?  It was a killing machine from the future, wasn't it?

MR. MOORE:  Your Honor, I'm going to object.  I think this is getting pretty far afield.  Mr. Porter's trying to suggest that some movie has some effect or influence on this trial.

MR. PORTER:  Your Honor, Mr. Moore has opened that door.

THE COURT:  Objection's overruled.  Go ahead.

BY MR. PORTER:

A.   [Continuing]  Yes, I believe that movie is based on a killing machine from outer space or whatever.

Q.   And, in fact, that was one of Chapel's favorite movies, wasn't it?

A.   I believe so, yes.

Q.   Let me ask you specifically about Brian Reddy.  You said you got to fire station at about 8:30, 8:35; right?

A.   Yes.

Q.   And Reddy walked in right behind you, didn't he?

A.   He -- Officer Chapel and Officer Reddy arrived about the same time.  They would've come in behind me, yes.

Q.   And that was within, according to your previous testimony, about five minutes; wouldn't you say that's right?

A.   I would think so, yes.

Q.   And Reddy stayed with you the whole night, didn't he?

A.   He left a few minutes before I did.

Q.   All right.  But that was around 10:15, 10:17, right after you called your wife; right?

A.   Yes.

Q.   So Reddy didn't even walk out of the fire station until after ten o'clock; isn't that correct?

A.   That's probably correct, yes.

Q.   Now, as a supervisor, it's probably not a great idea for you to sit in a fire station from 8:30 at night till 10:15 at night out of the weather, wouldn't you say?

A.   Yes.