georgia v. susan mccoy: bond hearing transcript
DESCRIPTION
Georgia v. Susan McCoy: Bond Hearing Transcript relating to restraining order in favor of Cobb County Board of Commissioners Timothy Douglas Lee.TRANSCRIPT
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IN THE MAGISTRATE COURT rOR THE COUNTY
GEORG ] A
15-W-10338
OE COBB
STATE OF GEORGIA
VS.
SUSAN JANETTE MCCOY
BOND REVOCAT I ON
BEEORE THE HONORABLE
MARCH, 2015.
AP PEARAIICE OF COUI.]SEL:
FOR THE STATE:
EOR THE DEITENDANT:
ROBERT G. HALVORSON
COURT REPORTER
P. O. BOX 1559
MARIETTA, GEORGJA 30061
( 1'ia) 528-8931
HEARING IN THE
JUDGE PHILIP P.
ABOVE-STYLED
TAYLOR, ON
CASE, HELD
THE 17 TH DAY
SHARLA JACKSON
MADDOX K I LGORE & CARLOS RODP.]GL]EZ
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WITNESS INDEX
PAGE NO.
TIMOTHY DOUGLAS LEE
DI RECT :
CROSS:
RED]RECT:
MD
MS.
JACKS ON
KILGORE
JACKSON
11
2A
3B
MICHAEL EMBRY PAR] S
DIRECT: MS. JACKSON
MR. KILGORE
4A
42
PAUL CAMARILLO
DI RECT :
CROS S :
REDIRECT:
RECROS S :
EURTHER REDIRECT:
MS. JACKSON
MR. K]LGORE
MS. JACKSON
MR. K]LGORE
MS. JACKSON
46
52
55
56
57
BETSY MANSTON
D] RECT : MS. JACKSON
MR. KILCORE
5B
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MATTHEW I.]ORMAN
DIRECT:
CROSS:
REDIRECT:
WlTI',]ESS II']DEX
JAC KS ON
KI LGORE
JACKS ON
PAGE NO.
6B
83
101
MS.
MR.
MS.
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THE COURT: SUSAN JANETTE MCCOY.
(I,^lHEREr,l POt'l. THE DEEENDAIIT EI.lTERED THE CCURTROOi,i. )
MS. JACKSON: YOUR HONOR/ DO YOU HAVE A COPY OF THE
STATE'S PETIT]ON?
THE COURT: YES, I AM READING IT NOl/.].
MS. JACKSON: OKAY.
(BRIEE PAUSE )
THE COUF,T: ALL RIGHT, THIS IS THE CASE OE THE STATE
OF GEORGIA VERSUS SUSAN MCCOY. THIS IS A PETITION TO
RF]VOKE BOND BROUGHT BY THE STATE REFEREI]CING SPECIEICALLY
WARRANT NUMBER 15-W-10338. IT'S THE STATE'S MOTION; I'LL
LF]T YOU GO FIRST.
MR. KILGORE: I,JE/RE ASKING FOR THE RULE.
THE COURT: WHO IS GOING TO BE A WITNESS IN TH]S
CASE?
THE COURT: ALL RIGHT/ WHOEVER __
MS. JACKSON: -- BETSY MANSTON AND MATTHEW NORMAI'1 .
THE COURT: WHOEVER IS NOT GO]NG TO BE CALLED EIRST,
HAVE A SEAT iT] THE LOBBY FOR ME . ViE' LL CALL YOU }.JHE}I WE
NF]ED YOU.
MS. JACI'{SOII r AIID YOUR HOllOR, BEFORE IrE CALL THE
V,]1TI']ESSES, ] JUST h]ANT TO GIVE YOU THE BACKGROUND.
MS. .TACKSON: TIM LEE, MICHAEL PARIS. PAUL CALARILLO
YOU PREV]OUSLY HEARD THE ALLEGATIONS OF TH]S CASE IN
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THE PROTECTIVE ORDER HEARING A FEW WEEKS AGO.
.UiANT TO GO T]EEP II'ITO THE EACTS.
DO YOU NEED __ DO YOU REMEMBER THE FACTS
THE COUP.T: SURE.
MS. JACKSON: -- OR DO WE NEED
THE COURT: I THINK ] DID -- I
THIS CASE. IT SOUNDS FAMTLIAR, BUT
YOUR RECORD __
WE DON'T
OE THE CASE
TO GO BACK INTO THEM?
DID OTHER HEAF.IIJGS IN
TF YOU WANT TO -_ 1T'S
MS. .IACKSON: oKAY.
THE COURT: -- IF YOU WANT TO GO INTO SOME
t OUNDAT]ONAL STUFE __
1"1S. .TACKSON: BASTCALLY --
THE COURT: -- YOU'RE WELCOME TO, BUT --
MS. JACKSON: __ THE ALLEGATIONS AP.E THAT THE
DEFENDANT, SUSAN MCCOY, EXPERIENCED SOME TYPE OF FIRE AT
HI]R HOUSE. SHE BELIEVED THAT IT WAS DONE IN RETAL]AT]ON
EOR HER SPEAKING OUT ABOUT ]SSUES AROI-]}ID THE __ THE
BRAVES' STADIUM BE]NG BUILT IN COBB COUNTY. AND iN
RF]TALIATION EOR HER BE]ING ANGRY ABOUT THIS BEING DOIIE/ THE
AI,LEGATIONS ARE, AND THE STATE !.i]LL PF,OVE AT TRIAL, THAT
THE DEEENDANT THEN PROCEEDED TO HARASS AND INTIM]DATE AND
STALK SEVEPAI PEOPLE INVOLVED WITH THE BUILDING OF THE
STADIUM/ INCLIJD]NG _. }^iELL, SAI'1 OLENS/ TT1E ATTORNEY
GENERAL, IS ONE OE THE PEOPLE THAT WAS __ HAS CHARGED THE
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DEFENDANT WITH STALKING H]M.
HlS STALK]NG INCLLIDED HER SENDING HIM MULTIPLE
EMAILS, GOII'JG TO HI.S HOUSE. PHOTOGRAPHING OBJECTS INSIt)E
HIS HOUSE. CONTACTING HIS CHILDREI.I AS A RESULT OF -_ SHE
WAS CHARGED T,.IITH STALKING/ AND I"1R. OLENS THEN ENDED TJP
GETT]t.JG A RESTRAINING ORDER AGAINST HER.
MICHAEL PARIS, WHO ACTUALLY LIVES A EEI^] DOORS DOWN
EROM THE DEFENDANT, IS ACTUALLY A PRIVATE CITIZEI'I . HE'S
TANGENT]ALLY INVOLVED IN ANY TYPE OF DEVELOPMENT THAT
TAKES PLACE IN COBB COUNTY.
SHE 1S ACCUSED OE -_ SHE h]AS II.]IT]ALLY CHARCTED I,/ITH
HARASSING COMMUI.]ICATIONS/ FOIT. SEI..iDING i"lORE THAI.I FIFTY-SIX
EMAII-S TO MR. PAR]S HARASSING AND ]I.,iT]MIDATING HIM, SOME
OF WHICH INCLUDED THREATS TO DO BODILY INJURY TO HIII OR TO
H]S FAM]LY. ONE OE THEM ALLEGED THAT SHE WOULD COMMIT
TARGET PRACTICE _- THAT HE HAD TO PASS HER HOUSE IN ORDER
TO GET TO HIS HOUSE. SHE STARTED TALKING ABOUT TAKING
TARGET PRACT]CE/ IdH]CH SHE TOOK _ b]HICH HE TOOK TC MEAN
THAT SHE TJOULD POSSIBLY TRY TO SHOOT HiM, OR DO BODILY
HARM TO HI}1.
AETER SHE WAS CAI,LED INTO THE POLICE DEPARTI"{ENT AND
ASKED NOT TO COMMUI..]I CATE WITH MF,. FAR]S, OR ANY OF THE
OTHER PECPLE, SHE THEN CONTII,iUED TO EMA]L. SHE EMAILED
MR. PARIS AN ADD]TIONAL T]ME. EOR U]HICH SHE I/iAS CHARGED
WTTH AGGRAVATED STALK]NG.
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CHAIRMAN LEE AND MICHAEL PARIS ARE VERY GOOD ERIENDS,
A FACT WHICII IS KNOWI'I TO THE DEFENDANT, AI.J D HE WAS ALSO
C]NE OT THE INITIAL REC]PIENTS TO TH]S __ TO THIS _- OT
TIlIS COMMUTJICATION.
AS A PUBLIC OEE]CIAL HE EXPECTED TO GET THIS TYPE OF
_- TO GET COMMUNICAT]ON EROM CIl'IZENS WHO OPPOSED ACT]ONS
THE COUNTY WOULD BE TAKING. HOI,{EVER, ON -_ AS OE LAST
!'JEEK, COMIIUNICATIONS SITARTED AGAII\l FROM THE DEEENDANT.
THERE'S SEVERAL PLACES WHERE CHAIRMAIJ LEE IS ].ISTED
II'] THE POLICE REPORT. THE STATE WOULD BE CALLIT]G HINI AS A
WITNESS AT OUR CASE, AI'']D ON LAST -- LAST F'R]DAY. EEBRUARY
TWENTY_S1XTH, AT EOUF O'CLOCK, THE DEEENDANT STARTED
COMMUNICATING !JITH CHA]RMAN LEE, THE LAST TEXT MESSAGE,
I.JHICH HAD TAKEN ON A HARASSING AND INTlMIDATING NATURE E'OR
HII'1.
THE OTHER _- IN ADDITION TO THE COMMU}JICATIONS, THE
SI]ATE IS ALSO ALLEG]NG THAT THE DEEENDANT SHOULD HAVE BEEN
EVALUATED AS PART OE HER BOND COND]T]O\IS. THE STATE HAS
GOTTEN lNI,ORI',IATION THAT THE DEFEI\]DANT HAS BEEN
HOSPITALIZED AT RIDGEVIEW, AND THE STATE __ IT'S THE
S]'ATE' S BEL] EF, Ti.tE STATE' S CONTEI']TION, THAT THE DEEENDANT
IS NOT ]N COMPLIANCE IA]ITH THE TREATMENT PLAN, OR ANY
T REA'IMEN'I PT,AN ,
WE STII,L DON'T KNOVI THE EEFECT __ THE OUTCOME OF
THOSE EVALUATIONS. I/iE BELIEVE THAT THE DEEENDANT 1S NOT
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IN A VERY GOOD MENTAL STATE AND IS NOT TAKING MEDICATION
THE STATE ALSO CONTENDS THAT THE __ BECAUSE OE THIS,
THE DEEENDANT IS AT HIGH RISK OE COMMITTING DANGEROUS ACTS
I,JH]CH COULD INJURE -- INJURE OTHER PEOPLE, AS WELL AS
HERSELF, AND WE/LL CALL OUR FIRST WTTNESS.
THE COURT: WELL, LET ME HEAR EROM MR. __ ] DON,T
KNOW WHO IS GOING TO TAKE THE LEAD ON THIS.
ANY OPENIN-G STATEMENTS YOU WANT TO MAKE?
MR. KILGORE: JUST __ JUST BRIEELY, JUDGE.
THE COURT: ALL RIGHT.
MR. KILGORE: THE PETITION TO
PARAGRAPH PETITION. ]'M NOT SAYING
ADMITTING TO ANYTHING FACTUALLY IN
__ ]F' WHAT IS ALLEGED IS TRUE, SHE
HER BOND.
REVOKE BOND IS A FOUR
THAT MS. MCCOY'S
THIS PET]TION, BUT IE
IS NOT IN VTOLATION OF
]E YCU'LL NOTICE, THEY ALLEGE IN PARAGRAPH THREE THAT
SHE'S IN VIOLATION OE BOND CONDITION NUMBER EIGHT,
PROHIBTING ]ND]RECT CONTACT WITH THE VICTIM IN THIS CASE,
MICHAEL PARIS.
WELL/ LET,S LOOK AT THE BOND CONDITION, NUMBER EIGHT;
DEF'ENDANT SHALL HAVE NO CONTACT IN ANY EORM, DIRECT OR
INDIRECT, WITH ANY VICTIM OR WITNESS IN TH]S CASE, TO
lNCLUDtr NO CONTACT WITH THE VICTIM,/WITNtrSS RtrE'trP.trNCtrD
i,{ORKPLACE OR SCHOOL.
THE DEEENDANT IS TO HAVE NO CONTACT WITH THE
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EOLLO!'iING INDIVI DUALS .
DO YOU SEE !^iHAT I, M _- DO YOU SEE !^JHAT I, t"1 LOOKING
AT, JLtCE, THE BOND _-
THE COURT: YES, S]R.
MR. KILGORE: ALL RIGHT.
AND SO -- THERE ARE NO WITNESSES LISTED IN THAT BOND
clRDER.
HOT{EVER, IF YOU TAKE A LOOK AT
15_W-10338, WHICH IS ALL WE'RE HERE
LOOK AT THAT. ON THE BACK ]T LISTS
THE WARRANT ECR
FOR/ IF YOU TAKE A
__ ^p rv _'ctr vE- 'l THf
FRONT IT LISTS THE I,\]ITNESSES: OEFICER KENNEDY AND JAMES
C],AYTON STARHOF,I']. THOSE ARE BOTH __ THOSE ARE BOTH POLICE
OEFICERS, OKAY ?
r!. .Trur. e.r^.itr, c <UGGESTING HERE THAT SOMEHOW BY --
IE MS. MCCOY COMMUNICATED IN ANY WAY WITH TlM LEE. THAT
SOMEHOVJ THAT VIOLATES HER __ HER BOND, ]T DOES NOT. SO, T
THINK __ I THINK THAT PRETTY MUCH JUST SETTLF]S THAT
ALLEGAT I ON .
CI] FARACRAPH __ I}] PARAGRAPH FOUR S]]E _- AT L SHE'-C
II']DICATING IS THAT THE DEFEI{DANT ]S A DANGER TO THE
COMMUN]TY AND HAS DEN1OIJSTRATED IRRATIONAL BEHAVIOR, AND
ALL THAT, S BEING ALLEGED IS APPARENTLY THAT SHE WENT TO
THE DlSTF.ICT ATTORNEY'S OEEICE AND HAD A CO}]VERSATION WITII
AN EMPLOYEE THERE. ] DON'T SEE HOW THAT'S -- HOW ANYTH]NG
ABOUT THAT IS __ VIOLATES HER BOND.
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WE'RE CERTA]NLY NOT ON ANY NOTICE OF ANY OTHER
ALLEGATION THAT SHE SAYS IS VIOLATTNG HER BOND COND]TIONS.
PART]CULARLY, SHE SAID SOMETHING ABOUT HER EVALUAT]ON.
I.JELL, PRETR]AL KNOhIS ALL ABOUT HER EVALUATION SITUATION.
THAT'S NOT BEEN PLED HERE, SO WE'RE NOT HERE ON THAT
TODAY. SO. WE WOULD OBJECT TO __ OBJECT TO ANY __
ANYTHING ABOUT THAT MATTER.
SO, I CAN GO INTO MORE DETAIL IF THERE'S ANYTHING THE
COURT WANTS TO KNOW, BUT BOTTOM LINE IS, I THINK THAT IT
SHOULD BE PRETTY SHORT AND SWEET.
THE COURT: DO YOU KNOW IF THIS IS SCHEDULED EOR --
FOR A PRETRIAL BOND REVOCATION?
MR. KILGORE: IT' S NOT.
THE COURT: OKAY.
MR. KILGORE: AS EAR AS PRETR]AL, S CONCERNED, SHE,S
IN COMPLIANCE.
THE COURT: ALL RIGHT, FIRST b]ITNESS.
MS. JACKSON: I WAS GO]NG TO CALL MR. LEE, BUT ],M
GO]NG TO GO AHEAD AND CALL THE PRETR]AL OEFICER EIRST.
THE COURT: OKAY.
MS. JACKSON: MR. LEE, COULD YOU STEP OUTSIDE AND I/M
GO]NG TO CALL MS. BETSY MANSTON.
MR. KILGORE: WEI-L/ I'M GOING TO OBJECT TO THAT. I'M
GOING TO ASK THAT MR. LEE BE CALLED EIRST, AND THE REASON
IS, HE SAT IN HERE DURING THE OPENING STATEMENT.
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THE COURT: YES/ YOU PROBABLY NEED TO CALL HIM EIRST
SINCE HE SAT THROUGH THE OPENING REMARKS.
MS. JACKSCN: I,dELL, HE, S NOT __ THERE, S NO REASON WHY
HF I,{OULD COMMUN]CATE !{ITH ANY OF THE OTHER WITNESSES '
THE COURT: r'iELL, I-ET'S -- LET'S NOT MUDDY IT UP-
HE __
MS. JACKSON:
THE COURT:
MS. JACKSON:
MR. LEE.
THE COURT:
THAT' S EINE .
__ SAT THROUGH THE OPENING REMARKS
THAT'S TINE/ I'LL CALL MR. LEE.
CCME ON UP, SIR.
TIMOTHY DOUGLAS LEE,
SWORN/ WAS EXAMINED AND TESTIFIEDHAVING BEEN FIRST DULY
FOLLOWS :
COMMISSIONERS.
FROM A SUSAN MCCOY?
AS
BY MS. JACKSON:
STATE YOUR NAME FOR THE RECORD.
A
A
MY NAME IS T]M __ TIMOTHY DOUGLAS LEE
DIRECT EXAMINAT I ON
HOW ARE YOU EMPLOYED?
I'M CHAIRMAN OE THE COBB COUNTY BOARD OE
AND DID YOU HAVE AN OCCAS]ON TO RECEIVE TEXT MESSAGES
A IN THE PAST I'VE RECETVED SEVERAL, BUT MOST RECENTLY
I RECEIVED ABOUT FOUR OE THEM, BEGINNING E'EBRUARY TWENTY-SIXTH.
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Q AND
A THE
h r^ltrT I T'T' --
MR. KILGORE
THE I,{ I TNES S
MR. K l LGORE
THE COURT:
GO AHEAD .
THE WI TI.,JES S
] OBJECT.
PARDON ME?
HIS REACTION ISN' T RELEVAI..]T.
WELL, I'M GOING TO OVERRULE THAT.
XT MESSAGES?
EIRST ONE WAS TO INVITE ME TO LUNCH' AND THE}'I THE
ASECOND ONE WAS TO PRESENT A -- A PICTURE' ASKING ME TO HAVE
BLESSED SLTNDAY.
THE THIF'D ONE WAS THEN A TEXT THAT SPOKE TO HER
INTENT TO SPEAK AT EVERY UPCOMING COBB COUNTY COMMISSION
|,IEE?iI]G. AF.C MEETING. U}ITII, SUCH TII'IE THAT SHE COULD BE PUT
INTO -_ SITUATED BACK INTO HER OWN HOME.
THE EOURTH WAS A}JOTHER PICTLIRE ASKING ME TO HAVE A
PEAC E F'UL DAY .
AND T,{HAT WAS YOUR REACTION TO YOUR RECE]VING THESE
TEXT I,IESSAGES ?
MY __ MY REACTION WAS THAT THIS _- THIS
.IEXT THAT __ SPECIFICALLY WHEN IT TALKED ABOUT COMING TO
..PE.A-K, Id.AS ONE THA.T SUCH SHE I^TAS TRYII'JG TO INTIM]DATE }iE
II.JTO ]NFLUE]I..]CING HER ABILITY TO GET BACK TO HER HOME. AND
'fHAT SHE l^lOLlLD CONTII]Utr TO S HOI,.j UP AT MtrtrTINGS AND HARASS
Ah]D INTI}lIDATE UNTlL ] DID SOI"IETH]IIG TO TRY TO INFLUENCE
THAT.
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I HAD HAD EXPERIENCE W]TH HER ]N THE PAST AT PUBLIC
HEARING MEETINGS, SPECIF]CALLY AT THE ATLANTA REGIONAL
COMMISSION, A COMMITTING MEET]NG WHICH I CHAIR, WH]CH SHE
WAS ASKED REPEATEDLY TO STOP SPEAKING, EOLLOWING THE RULES
OF THE PUBLIC SPEAKING, WH]CH SHE IGNORED AND CONTINUED TO
RAISE HER VOICE, AND ACTUALLY GET LOUDER IN THAT REGARD.
BASED ON MY OWN PERSONAL H]STORY, THE TACT THAT I HAD
HEARD TO SOME DEGREE THAT SHE HAD HAD A __
MR. KILGORE: I AM GOING TO OBJECT TO WHAT HE HEARD.
Q (BY MS. JACKSON) WHAT DID YOU DO __
THE COURT: THAT WOULD BE HEARSAY.
Q (BY MS. JACKSON) WHAT DTD YOU DO AS A RESULT OE WHAT
YOU HEARD?
A I{HAT I DID WAS ] DIRECTED THE COUNTY MANAGER TO
SECURE THE THIRD E'LOOR OF MY BUILD]NG WHERE I SIT ON.
I ALSO ASKED EOR POLICE ROTAT]ON AROUND MY HOME.
I ALSO WORKED WTTH AN ESCAPE PLAN FOR MY FAMII,Y AND
PUT IN A V]DEO SURVE]LLANCE SYSTEM IN MY HOME BECAUSE OE THE
THINGS ] HEARD THAT HAPPENED WITH CHAIRMAN OLENS __ OR ATTORNEY
GENERAL OLENS. I THOUGHT IT WAS IMPORTANT TO HAVE A VIDEO
SYSTEM AVA]LABLE.
AND BASICALLY WE'VE BECOME AT A H]GHER LEVEL OF
AWARENESS AS TO YOUR SURROUND]NGS EVERYWHERE WE GO BECAUSE OF
THE EEEL]NG THAT __ THAT WE' RE NOT QUITE SURE THAT TO __ TO
WHERE'S THE END LINE IN THIS -- IN THIS CONVERSATION.
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SO THE EMA]LS, PAST EXPERIENCE/ LED ME TO TAKE ACTION
TO TRY TO MAKE SURE THAT MY __ MY AND MY FAMILIES ARE SAFE, AND
I THEN -- BECAUSE SHE INDICATED SHE WANTED TO GET BACK IN HER
HOME/ KNOW]NG THAT HER HOME IS NEAR MR. PARIS, I SHARED IT I{ITH
MR. PARIS AS WELL.
MR. KILGORE: JUDGE, I'M GOING TO OBJECT. I'M GOING
TO OBJECT TO A POLITICAL SPEECH, AND I WOULD ASK THAT THE
COURT DIRECT COUNSEL TO ASK A QUESTION, AND THAT WE DO A
QUEST]ON AND ANSWER THE WAY h]E DO IT IN COURT/ NOT __ NOT
ON THE __ NOT ON THE CAMPA]GN TRAIL.
MS. JACKSON: WE __ WE WOULD ASK THAT THE DEEENSE
MAKE A LEGAL OBJECTION.
THE COURT: ] DON,T THINK THAT, S A LEGAL OBJECTION.
MR. KILGORE: EORM OF THE QUESTION.
THE COURT: I,M GOING TO OVERRULE IT.
GO AHEAD .
(BY MS. JACKSON) GO AHEAD; CONTINUE, MR. LEE.
SO THE BOTTOM L]NE IS THAT I WAS -- RECENT
COMMUNICATION AND THE PAST HTSTORY, AND KNOWING WHAT/ S BEEN
DONE AT OTHER ELECTED OEEICIAL'S OFFICE. I EELT THAT I I.JAS
BEING INTIMIDATED, ] WAS __ ] WAS GOING TO CONTINUE TO BE -_
CONTINUED TO BE HARASSED, AND AS SUCH, EVEN TODAY, ] STT __ I
MAKE SURE THAT ] DO I,iHATEVER I CAN TO BE AWARE OF MY SITUAT]ON
OVER WHAT ] NORMALLY DO,
AGA]N, KNOWING I'M A PUBL]C OEEICIAL, ]'M GOING TO BE
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SUBJECT TO PEOPLE WANTING TO TALK TO ME, BUT NOT TO THIS
DEGREE, IE I HAD ANY OF THIS K]ND OT EXPER]ENCE.
AND AGAIN, BECAUSE ]T INDICATED SHE WANTED TO GET
INTO HER HOME, AND I KNEW SHE __ KNOW SHE L]VED NEAR MR. PARIS.
I ADVISED H]M THAT SHE WAS APPROACHING ME TO TRY TO --
MR. KILGORE: I DON,T KNOW HOW THAT WHATEVER HE
ADVISED MR. PAR]S COULD POSS]BLY BE RELEVANT, JUDGE.
THE WITNESS: I WOULD __ HAD CONCERN EOR HIS WELL
BEING.
THE COURT: ALL RIGHT, GO AHEAD AND ASK THAT
QUEST ION .
THE COURT: YOUR RESPONSE, MA,AM?
MS. JACKSON: ACTUALLY, WHAT HE -. PART OF WHY HE,S
HERE IS BECAUSE OF HIS RELATIONSHIP WITH MR. PARIS. HE'S
-- I I/iAS ACTUALLY GOING TO FOLLO!{-UP !{ITH ANOTHER QUESTION
TO EXPLAIN THE RELAT]ON __ HAVE H]M EXPLAIN THE
RELATIONSHIP BETWEEN H]M AND MR. PARIS, AND WHY MR. PARIS
WOULD HAVE HAD A REASON TO KNOW ABOUT THESE TEXT MESSAGES,
BETORE WE WERE INTERRUPTED BY THE DEEENSE.
Q (BY MS. JACKSON) WHAT IS YOUR RELAT]ONSHIP WITH MR.
PARIS, AND HOi^] IS IT HE I^JOULD KNOW ABOUT THESE TEXT MESSAGES?
A MY -- ] __ I'VE KNOWN __ HE WORKS WITH COMMUNITY
GROWTH WITI] HIS ORGANIZATION THAT HAS INTERACTION WITH TI]E
BOARD OF COMMISSTONERS EREQUENTLY. WE SEE EACH OTHER AT PUBLIC
EVENTS ALL THE TIME. ]/VE HAD OCCASION TO BE AT HTS HOME
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SEVERAL T]MES AND VIS]TED I,dITH HIM AND H]S WIEE AND HIS EAMILY,
AND I WAS AWARE OE HIS PROXIMITY OE HIS HOME TO THE MCCOY
]NCIDENCE, SPECTFICALLY BECAUSE OE THE ISSUES THAT OCCURRED AT
HER HOUSE EARLIER/ AND THE LOCATION ASSOC]ATED WTTH THAT.
BECAUSE I KNEW THAT MR. *- THAT THE RESTRAINING ORDER
AGAINST HER TO MR. PAR]S, THE INDICAT]ON THAT SHE WANTED TO GET
BACK INTO HER HOME, I FELT MR. PARIS NEEDED TO DO __ KNOW ABOUT
THAT ON HIS OWN ACCORD. SO. THAT'S WHY ] SHARED THE TEXT
MESSAGES WITH H]M.
A SHORTLY AETER RECEIVING THEM. ] DON' T REMEMBER
SPECIFICALLY, BUT SHORTLY AETERWARDS.
Q AND WHAT PO]NT __ WHEN DTD YOU SHARE THE TEXT
MESSAGES WTTH HIM?
Q ALL RIGHT.
MS. JACKSON: ] KNOW YOU, RE __ YOU HAVE COPIES OE
THEM ON YOUR PHONE, AND JUST EOR PURPOSES OF THE RECORD
I'M GOING TO SHOW YOU THESE STATE'S EXHIBITS. I'M GOING
TO CALL THEM ONE, TWO, AND THREE.
MR. KI]-CORE: I,M GOING TO OBJECT. THESE ARE CLEARLY
INCOMPLETE. ]E YOU TAKE A LOOK, IT STARTS IN THE MIDDLE
OE A SENTENCE.
MS. JACKSON: YOUR HONOR, WE'RE -- THESE ARE THE --
1/M GOINC TO HAVE THE WITNESS AUTHENTICATE THESE EXHIBITS.
WEI RE ALSO GOING TO HAVE OUR I^IITNESS ACTUALLY SHOW YOUR
HONOR, AND THE DEFENSEI THE TEXT MESSAGES ON HIS CELL
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PHONE. 1T WAS D]EEICULT TO GET EXACT SCREEN SHOTS OF THE
_- EXACT SCREE}I SHOTS OE THE COMPLETE TEXT IqESSAGES, BUT
WE WILL MAKE SURE THAT THEY ARE COMPLETE.
MAY I APPROACH THE WITNESS?
THE COI:]RT : ALL RIGHT, GO AHEAD.
Q (BY MS. JACKSON) I'M GOING TO SHOW YOU WHAT' S BEEN
MARKED STATE'S EXHIBITS OI.JE, TWO A}.]D THREE. CAN YOU IDEI.]TIEY
IT] LJ trM DT trAqtr?
A THE FIRST PAGE IS THE MAJORITY OF THE TEXT THAT I
RECEIVED ON FRIDAY N]GHT, AND THE ONE THAT I RECEIVED OI'] SUNDAY
MORN I NG .
NUMBEF. TWO ]S THE MAJORITY OF THE TEXT THAT
RECEIVED ON TUESDAY MORN]NG, MARCH F]RST.
AND THEN NUMBER THF.EE IS THE BALANCE OE THAT TEXT
FROM MARCH
TEXT THAT
O
MI-sSIiiG, BUT THE PHCTOGRAPHS ARE IN'TACT.
Q CAN I,^JE SEE YOUR PHONE , PLEASE ?
AND ]T STAP.TS HERE ?
THIS IS lHE FlRSl TEXT.
OKAY.
!.IRST, AND A PHOTOGRAPH AI'JD __ THAT -- PART OF A
I RECE]VED LATER THAT SAME DAY.
AND SO ] GUESS I MIXED __ I MIXED THE ORDER UP A
L]TTLE BIT, BUT ARE THOSE PHOTOGF.APHS COMPLETE RE PRESEI,]TAT ] ONS
OE THE TEXT MESSAGES THAT YOU RECEIVED FROM THE DEFENDANT?
A THE PHOTOGRAPHS -- THERE _- THERE'S SOME WORDS
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A AND THEN THIS.
Q ALL RIGHT.
MS. JACKSON: YOUR HONOR, MAY I APPROACH?
THE COURT: SURE.
Q (BY MS. JACKSON) AND HAVE WE SPOKEN ABOUT THIS CASE
IN THE PAST ?
A YES.
Q AND WOULD YOU EXPECT TO TESTIEY AS A WITNESS EOR THE
STATE IN THIS CASE?
A YES.
Q WHAT DID YOU DO AETER YOU SHOWED THOSE TEXT MESSAGES
TO MR. PARI S ?
A I DIRECTED MY COUNTY MANAGER TO SECURE THE THIRD
FLOOR. I ADVISED THE COBB COUNTY POL]CE DEPARTMENT, WHO
ADVISED THE SHERIEE, S OEFICE; I INFORMED MY STATE AS TO WHO MS.
MCCOY !,iAS IN THE EVENT SHE WERE TO SHOW UP ON MY ELOOR. BE
ADV] SED OF WHO SHE U]AS .
I SECURED VIDEO SECURITY FOR MY HOME AND WORKED ON A
SAFETY PLAN FOR MY FAM]LY, AND I ADVISED THE ATLANTA REGIONAL
COMM]SS]ON THAT MS. MCCOY INDICATED SHE WOULD BE SPEAK]NG DOWN
AT __ AT THE ATLANTA REGIONAL COMMISSION AS WELL. MORE OR LESS
ALERTED THOSE APPROPRIATE PEOPLE.
I ADVISED MR. PARIS THAT SHE HAD R.EFERENCED BEINC __
MOVING BACK INTO HIS __ HER HOME, !^JHICH IS AROUND THE CORNER.
AGAIN, BEING M]NDEUL OF THE RESTRICTIONS ASSOCIATED WITH THAT
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S]TUATION, I EEL]] IT I,{AS IMPORTANT HE KNOW THAT.
Q WHAT DID YOU EEEL HEF, iilTEllT ''tlAS iiiJ SEliDil'iG THAT
MESSAGE TO YOU ABOUT THE S]TUATION AT HER HOUSE?
MR. KILGORE: THAT -_ THAT CALLS EOR SPECULATION,
MS. JACKSON: HE
]S PEREECTL' ABLE TO
V,]HAT THE DEFE}IDANT' S
NOT BE -_
I'1S. .lACKSOI']
MR. KILGORE
QUESTION.
OBVIOUSLY, JUDGE.
MS. .TACKSON
ACTIONS __
__ A WITNESS OR VICT]M __ A WI'INESS
TALK ABOUT WHAT THE]F. BELIEF IS OE
IT'S VERY CLEAR __
IT'S CLEARLY NOT AN APPROPR]ATE
I]']TENT !^JAS . IT' S NOT A -- THAT VJOULD
MR. KILGORE: IT'S TRYII,JG TO GET INTO HER MII.ID,
.TUDGE. THEY'RE OBVIOUSLY BENIGN. AND -_ AND I'M GOI}JG TO
OB.-TECT TO HII"I SPECULATING ON SOMETHING.
HE CAN TALK ABOUT TAKING CERTAIN
MR. KI LGORE
MS. .IACKSON
MR. KILGORE
WELL __
__ ABOUT' CERTAIN TH]NGS.
YOU CAN HEAR ABOUT THAT ACTION, AND
I,LL QUESTION HIM ABOUT THAT, BUT HE -_ HE __ T^]E'RE
TALKING ABOUT GETTING TNTO THE ViOMAN'S MIND NOInl . THAT'S
CI-EAPLY NOT .AN APPROPRTATE QUESTION,
MS. JACKSON: AND ACTUALLY, FOR THE PURPOSES OE BOND,
IT'S '1'HLJ ['E/\R AND -LN'.1'-LMlI]AT]ON THAT I4ITNESSES EEEL, WH]CH
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IS WHY ONE OE THE BOND CONDIT]ONS IS THAT THEY NOT HAVE
CONTACT WITH VICTIMS OR I1JITNESSES. SO, MR. LEE,S ]NTENT,
BELIEE OE THE DEEENDANT,S INTENT, ]S ABSOLUTELY RELEVANT
IN THIS CASE.
MR. KILGORE: ACTUALLY, JUDGE. WHAT MATTERS IS, DTD
SHE VIOLATE THE BOND CONDITIONS? THAT'S WHAT'S RELEVANT,
NOT WHATEVER HE THOUGHT ABOUT SOME __ SOME __
MS. JACKSON: AND THE BOND CONDITIONS WOULD BE THE
DEFENDANT'S ATTEMPT TO INELUENCE, HARASS, OR INTIMIDATE
WITNESSES, BY HAVING INDIRECT __ DIRECT OR INDIRECT
CONTACT I,"JITH ANY OE THOSE VTCTIMS OR WITNESSES. THAT IS
THE PURPOSE FOR SETTING SUCH BOND CONDITIONS.
THE COURT: WELL, ] TH]NK HE CAN TESTIEY AS TO WHAT
ACTIONS HE TOOK WHEN HE RECEIVED THIS, BUT I DON'T KNOW IE
HE CAN TESTY TO WHAT HER __ WHAT HER INTENT WAS. I,M
GOING TO SUSTAIN THE OBJECT]ON.
MS. JACKSON: OKAY.
NOTH]NG FURTHER OF THIS WITNESS.
THE COURT: CROSS EXAMINATION.
CROSS EXAMINAT I ON
BY MR. KILGORE:
Q OKAY, AND MR. LEE. YOU __ YOU SAID YOU WERE ON SOME
PRIOR trMAILS trROM MS. MCCOY?
A TEXTS, YES.
Q EMAILS AND TEXTS.
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WHEI..I -- WHEN DID YOU RECEIVE THOSE?
I DON/ T RECALL, SIR.
ALL F.IGHT.
!^IELL, DI D YOU P,ECE IVE SOME I I'J OCTOBER OE TWO THOU SAND
EI FTEEN?
MS. JACKSON: YOUR HONOR, I'M
BEING -- WE HAVE KEPT THE INQU]RY
THE PURPOSES OE THE BOND I'M GOING
]NTO ANYTHIIIG OUTSIDE OE THE SCOPE
rOR THt BOND HEAPINC.
GO]NG TO OBJECT TO IHIS
VERY NARROW AS __ FOR
TO OBJECT TO HTM GOING
OE WHAT WE NEED TO DO
l.'lR. KILGORE : AND I --
l.ls. JACKSON: HE IS GOING OUTSIDE Or SCOPE OF THE
DIRECT EXAI'{IT]ATION.
MR. KILGORE: AND I WOULDN'T QUESTION HIM ABOUT IT,
EXCEPT THEY BROUGHT IT UP. THTS CAME OUT IN D]RECT. HE
TESTII-IED, YES, ] PECEIVED OTHER EMAILS AND TEXTS FP,OI{ HER
]N THE PAST.
THE COURT: CROSS EXAMINATION IS PRETTY BROAD iN
GEORGIA, SO ]'LL GO AHEAD AND ALLOW SOME OT IT, BUT AT
SOME POINT IT DOESN'T BECOME RELEVAIIT. SO/ I'LL LET YOU
GO AHEAD I{ITH THE INITTAL INQU]RY.
l'IR. KILGORE: SURE . I THINK I CAtt GET RIGHT TO IT .
Q (BY MR. KILGORE) DO YOU HAVE AIIY IDEA HOW MANY
EMAILS OP. TEXTS YOU RECE]VED EROM MS. MCCOY PREVIOUS TO THESE
EOUR THAT YOU'VE D]SCUSSED?
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NO, SIR, I DON'T RECALL.
OKAY.
WAS IT MORE THAN
A I DON'T RECALL,
Q ALL RIGHT.
WAS ]T MORE THAN
A I BELIEVE SO,
Q OKAY.
WAS IT MORE THAN
A I DON'T RECALL.
Q AND SO WHATEVER
INCONSEQUENT]AL YOU DON' T
CORRECT ?
I.T!..Iv^
NOT ONCE
COME UP
TEN ?
CTD
THEY WERE, THEY WERE SO
EVEN REMEMBER HOW MANY YOU GOT,
TWENTY ?
ONE ?
A SIR. I GET THOUSANDS OF EMAILS AND TEXTS OVER THE
COURSE OE TIME. ] DON'T RECALL HOW MANY ARE SENT TROM EACH
INDIVIDUAL, OR WHEN THEY DO. THOSE WERE HANDLED AT THE TIME.
WE'VE MOVED ON. THINGS WERE PROCEEDING NICELY, UNTIL I GOT
THESE BEGINNlNG OF EEBRUARY TWENTY_SIXTH WHERE IT CAME BACK UP.
OKAY.
ALi RIGHT, SO HOWEVER MANY YOU GOT, TEN/ TWENTY,
HUNDRED, HOW MANY EMA]LS OR TEXTS YOU GOT EROM HER,
D]D YOU EVER NOT]TY THE DISTRICT ATTORNEY'S OFFICE OR
HERE TO MAGISTPATtr COURT TO SEEK A WARRANTI DTD YOU?
A
O
PERSONALLY?
OKAY .
NO, I DID NOT.
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DID YOU HAVE MICHAEL _. DID YOU ASK
CONE UP HERE AND GET A I,iARRANT ]NSTEAD?
A NC. SIR.
Q OKAY.
MICHAEL PARIS TO
WAS, THAT I HAD RECEIVED SEVERAL EMAILS OVER THE COURSE OF
SEVERAL DAYS EROM MS. MCCOY. DURING A CONVERSATION OE' THE
EVENTS ASSOCIATED WITH MF.. PARIS AND THE ATTORNEY GENERAL, THIS
ISSUE !^IAS BEING ADDRESSED.
MY EMA]LS AND TEXTS WERE MADE AVAILABLE TO THE TOLKS
THAT WERE INVOLVED, AND AT THAT TIME THEY DIDN'T -- I WASN'T
BROUGHT INTO THE -- AS A WITNESS OR AS A -- AS PART OE THE .-
WTJATEVEP YOU GUYS DO,
SO WHATEVER HAPPENED ]N THE PAST/ AS EAR AS YOU WERE
CCNCERNED, IT CERTAINLY DIDN'T WARRANT HAVING POLlCE
INVOLVEMENT, CORRECT ?
NO. SIR, THAT'S NOT bIHAT I SAID. SIF., WHAT ] SAID
OKAY.
BUT 1T WAS INDICATED THAT I WOULD POSSIBLY BE BROUGHT
FORWARD IN THE EUTURE FOR WITNESS AS __
AND WHEN YOU SAY BElNG ADDRESSED, YOU MEAN SOMEBODY
ELSE WAS GOING TO GO GET A WARRANT. NOT YOU?
CORRECT.
OKAY,O
YOU SAI D
AND
THAT
SO YOU TALKED ABOUT TAKING A COUPLE OF MEASURES,
YOU NOTIE]ED THE SHERIEE'S OEEICE, TOLD THE
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EoUNTY MANAGER TO SECURE
SURVEILLANCE IN. THERE,
SOME DISCUSSION V{ ITH THE
OE'EI C IAL ACTION, RIGHT?
ilns THrno rr,oon, PUT vrDEo
S A HIGHER LEVtrL OE AWARtrNESS' YOU HAD
SHERIEE, S 9EEICE. THIS IS ALL
QUESTION.
POSITION AS COUNTY
A I,M NOT SURE ] UNDERSTAND YOUR
Q !{ELL, YOU, RE DOING IT IN YOUR
C HAI RMAN ?
A WHEN I DIRECTED COUNTY _- WHEN I DIRECTED THE CCUNTY
MANAGERToSECURETHETHIRDFLooR/THATWASDONEASMYOEE]CTAL
CAPACITY TO _- IN THE BEST INTEREST OF THE COUNTY. WHAT I __
Q WHEN WAS THAT DONE?
A iT WAS EITHER MONDAY OR TUESDAY, THE DAY EOLLOW]NG
THIS.
Q OKAY, MONDAY __ MONDAY OR TUESDAY, SO WE'RE TALKING A
WEEK AGO? MARCH, TWO THOUSAND SIXTEEN?
A A COUPLE __ WELL, WHAT'S TODAY'S DATE?
Q THE SEVENTEENTH.
A SO, IT HAD TO BE EARLIER -- YEAH, EARLIER THIS MONTII.
Q OKAY.
A AS IT RELATES TO MY HOME?
Q UH-HUH (AFEIRMAT]VE) .
A THERE'S NOTH]NG OFFICIAL ABOUT THAT.
Q ALL RIGHT, BUT WHEN DID YOU PUT V]DEO SURVEILLANCE
IN?
I DON'T RECALL.
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Q ALL F.IGHT.
WAS ]T MARCH, T!{O THOUSAND SIXTEEN?
A I DON'T RECALL.
Q !,IAS IT EEBRUARY, TWO THOUSAND STXTEEN?
A S]P' _-
) IdAS . T BLTOPE -HR]STMP.S:
A YES.
Q OKAY, SO IT WAS MAYBE DECEMBER?
A S]R?
Q WE,RE GOTNG TO SUBPOENA IT/ SO -_
A EINE; I,M TELLING YOU I DON,T RECALL, SO I DON, T CARE
HOi,{ MANY TII'IEI] YOU ASK ME, I' M NOT GOING TO RECALL .
Q ALL F.IGHT.
SO THE BOTTOM LINE IS. WHEN YOU TESTIFIED OI.] DIRECT
YOU TRIED TO GET THE MAGISTRATE TO BELIEVE THAT THIS IS SOME
ACTION YOIJ TOOK IN RESPOI]SE TO THESE EOUR LITTLE EMAILS A FEW
DAYS AGO, THAT'S NOT TRUE, IS IT?
S]R __
YOU PUT IN VIDEO SURVEILLAIICE I"IONTHS AGO.
vrrc rrl- Tc Uce
OKAY.
ALL R]GHT, THE _. THE TEXTS THAT YOU RECEIVED, YOU
DIDN'T CALL THE SHER]FF' S OFETCE A}.]D GO TRY TO SEEK A b]ARRANT
EOR MS. MCCOY'S ARREST FOR AI.]YTH]NG IN THESE COMMUNICATIONS.
DTD YOU?
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I']O, I CALLED THE POLICE DEPARTMENT, IS WHAT I SAID.
UH-HU'I (AEFIFMATlVL) .
A AND THE POLICE ADVISED THE SHERIEE'S OEE'ICE, SII'ICE
THE SHER]F'F'S OFEICE T,{AS -- IS INVOLVED I,^JITH SECURITY TO I'4Y ^-
TC THE _- THE COURT COMPLEX IN MY BUILDING.
A
ALi RIGHT.
I4HAT -_ DO YOU REMEMBER WHA? POL]CE OEE]CER YOU SPOKE
DIRECTOR HEATON.
OKAY.
AND D]D YOU SHARE WITH HIM THE CONTEXT, THE CONTENT
OT THESE TOUR MESSAGES ?
A WE DID.
Q ALJ- R]GHT.
TO?
SO THE DIRECTOR OF THE
THESE COI,IMUI! I CAT IONS, AND AS FAR
TAKE}] FOR AI]YTHING THAT SIIE DID/
COMMUN]CATIO}IS ?O YOU, RI GHT ?
POLICE DEPARTMENT WAS AT^TARE oE
AS YOU KNOW, NO WARRANT WAS
ALI,EGE DI,Y, IN THESE FOUR
IN FACT, TOI.D YOU THAT TH]S
A
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I HAD IJO I DEA OF KI.,]OWING ],HAT .
Q OKAY.
WEL],, DiRECTOT HEATON.
WAS NOT A CRIME/ DIDN'T HE?
A I DON'T RECALL WHAT HE __
I HAD RECEIVED, AND TOLD H]M THAT IIN]T]MIDATED AND HARASSED, AND HAD A
HE._ T ADVISED HTM OF
EEI,T THAT ] WAS BEING
CONCEF.N AS TO WHAT THtr2b
WH A'I
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FINAL INTENT WAS OE MS. }ICCOY. AS SUCH, WOULD HE, AS A PUBL]C
SAEETY DIRECTOR, PLEASE TAKE THE APPROPRIATE ACTICI'IS ASSOCIATED
WlTH TT.
OKAY.
ALL RIGHT, SO YOU WENT TO THE VERY TOP, AND WAS TIIIS
A _- I,JAS AI'] OEFICIAL REPORT MADE, OR WAS THIS JUST A TELEPHON*E
CALL THAT YOU HAD I{ITH THE DIRECTOR?
A I HAD A TELEPHC},IE CALI. AND A PERSONAL VISIT.
\2 OKAY.
AND THIS WAS !./HAT / A WEEK AGO, OR SO?
A OR SO.
Q OKAY.
AND YOU W]IRE NEVER ASKED TO COME BACK DOWN HERE AND
MAKE A STATEMENT TO ANY OEEICER, OR BEFORE A MAG]STRATE,
CORRECT ?
A
O
CORRECT.
ALL RIGHT.
SO, LETI S GE? INITO
ARE. YOU STILL GOT
I SURE DO.
ALI, RIGHT.
?HE CONTENT OF -_ OF WHAT THESE
YOUR PHOI.IE t,.J I TH YOU?ME S SAGE S
A
O
SO, ]E YOU WOULD, PLEASE,
REAL COOD, DO YOU MTND F.EADIIJG WHAT
A HI, CHAI RI"IAN LEE. SUSAN
]E YOU WANTED TO GRAB LUNCH OUT, ON
BECAUSE THE COPIES
THE F]RST MtrSSAGtr
MCCOY HERE. WANTED
ME. I,[E COULD TALK
WEREN / T
SAYS ?
1'O 5EE
ABOU T
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AND YOU- CERTAIIJLY AGF.EE THAT IiOV.IHERE iI'I THAT
COMMUN]CATION D]D SHE DIRECT YOU TO CONTACT ANYBODY ON HER
BEHALF?
THE EUTURE OF COBB.
THAT WAS SENT TEBRUARY TWENTY-SIXTH, AT F]VE TEN.
Q OKAY.
A THAT' S CORRECT.
Q OKAY.
A NO.
Q ALL RIGHT.
SO WHEN DI D YOU RECEIVE THE SECOND OI,JE?
A EEBRUARY TT.iENTY_EIGHTH, AT EIGHT THIRTY_EOUR A.M.
Q ALL RIGHT/ SO THIS _- THAT WAS TWO DAYS LATER THEI!?
a , trc
Q OKAY.
AND CAI'J YOU READ THAT ONE. PLEASE?
A IT SAYS, I]AVE A BLESSED SUN]DAY/ AND TT HAS A
PHOTOCRA PIr Or A I.AdE.
Q OKAY.
AND YOU AGREE IN THAT COMMUN]CAT]ON SHE CERTAINLY
MADE }JO __ NO THREAT TO YOU ]IJ ANY WAY?
A THAT'S CORRECT.
Q A],L RIGHT.
AND WAS TFiERE AN IMAGE THAT WEI.,]T ALONG WITH THAT
EIRST COMMUNICAT ION ?
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A
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AND YOU CERTAINLY WERE NOT PERSO}JALLY INTIMlDATED BY
HER WISH]NG YOU A BLESSED SLINDAY, I^IERE YOU?
A SIR, ]T'S THE INTENT BEH]ND THE MESSAGE AS TO !,iHY SHE
WOULD SEND ONE TO ME OI'] FEBRUARY TWENTY_EIGHTH. I TOOK NOTE
AND TOOK CONCEP.N THAT I'D GOTTEN A __ RECEIVED A TEXT FROM HE.R
SUNDAY MORNING, REGARDLESS OE THE CONTENT.
OKAY.
IT WAS A COMMUN]CATION.
BUT SHE DIDN'T USE ANY THREATENIIIG LANGUAGE WITH YOU,O
DID SHE?
A
0
BEHAL F,
NO, SIR.
AND SHE DIDN'T ASK YOU TO CONTACT ANYBODY ON HER
DID SHE ?
NO, SIR.
ALL RIGHT.
SO, THE -_ i,iHEN hiAS THE THIRD MESSAGE YOU RECEIVED?
TUESDAY, I'iARCH FIF.ST, AT SI:{ O T},IO ITI THE I.IOR}iII.]G.
OKAY.
AND THIS ]S ALL BY liAY OE TEXT, RIGHT?
YES, SIR.
SHE DIDI]'T CALL YOU TO HAVE A PHONE CONVERSATIO}J?
l'lo, SIR.
ALL RIGHT.
AND WHAT DOES THE THIRD ONE SAY?
DEAR CHA]RMAN LEE, I'LL BE SPEAKING PUBLICLY AT EACH
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AND EVERY UPCOMING COBB COUNTY COI'{MISS]ONER'S MEETING, AND
BY THOSE WHO SERVE THE PUBLIC INTEREST. I'LL ALSO READ POETRY
ATLAI]TA REGIONA], COMI,{ISSIONER'S }IEETING U}ITIL SUCH T]ME THAT ]
CAN GET SITUATED BACK INTO MY VERY OWN HOME. I'LL BE SPEAKING
ABOUT LEADERSHIP, TRUST, INTEGRITY, AND SIMILAR VIRTUES DESIRED
II'J KIND. KINDEST REGARDS/ SUSAN MCCOY. AND TT HAD A
PHOTOGRAPH OE A BOOK.
OKAY.
AND THIS IS ONE OE THE COMI"]UN I CAT ION S THAT YOU SHARED
i,\r I TH DIRECTOR HEATOII?
A
OKAY.
AND YOU AGREE THERE'S CERTAIT]LY I.JO DIRECT THREAT TO
THE FACT THAT SHE WOULD __ SHE'S ACTUALLY STATING THAT SHE'S
GOING TO BE SHOWING UI] AT MEETINGS AND SPEAKING TO I]S UNTIL SHE
GETS SITUATED BACK ]I] HER HOME. IT'S UX]T]L SHE GETS SITUATED
BACK IN HER HOME THAT RA]SED COI\]CERN W]TH ME THAT THE INTENT
WAS TO HARASS AND INTIMATE UNT]I, SUCH TIME THAT I DID SOMETHING
TO ACCOMMODATE T IIAT STATEMEI.JT.
YOU I}J THIS LANGUAGE EITHER, IS THERE?
AGAIN, SIR. IT'S NOT THE LANGUAGE AS MUCH AS ]T IS
IF THE __ IF THIS TEXT HAD NOT REFERRED TO HEF. BE]NG
HAVE NOTHTNC TO DO ABOUT,SITUATED BACK INTO HEII HOME/ WHICH I
I MAY T]OT HAVE HAD THE SAME CONCERN,
RED F'L.AG FOR ME A.ND MY CONCERN.
BUT 1HA'1'' S WHAT RAISED THE
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OKAY .
AND SO WE,RE TALKING ABOUT A COBB COUNTY
COMM]SSIONER, S MEETING; THAT IS OPEN TO THE PUBLIC. RIGHT?
A YES, SIR.
AI'ID SO AS A MEMBER OF THE PUBLIC. SHE, S CERTAII{LY
COME THERE ATID OBSERVE AND TO MAKE STATEN]ENTS ON __ ON
CORRECT ?
THAT' S CORRECT .
AND THE SAME AS THE ATLANTA REG]ONAL COMMISSlON?
YES, SIR.
ALL RIGHT.
ABLE TO
ISSUES,
A
O
A
O
AND THAT'S A PUBLIC FORUM, AND PEOPLE LIKE MYSELF AND
SUSAN MCCOY CAN COME AND MAKE STATEMENTS OI] ISSUES, WHATEVER IT
]S THE COMM]SSIO}J'S DO]NG, CORRECT?
A THERE TS GUIDEL]I,IES FOF, PUBLIC COMMENT PERIOD AS TO
rT'll tr ar'll,t!.trl,tT ,l-uE- nrD7 rnc. u,^ECTIOlJ, THE ?IME LIMIT, AllD My EXpEp.IEIiCE
WITH MS. IICCOY ]N THE PAST IS SHE __ SHE -- GIVEN THE
OPPORTUNITY TO SPEAK AS YOU SUGGESTED, BUT IGNORED THE TIME
I,IMITATIONS AND DIRECTION TO STOP TALK]NG WHEN SHE/S EXTENDED
BEYOND THE TIME LIMIT, AND ACTUALLY ROSE HER VOICE WHEN THE
CALL WAS ASKED TO __ EOR HER TO SIT DOVJI,J A},]D COMPLETE IIER
COMI{ENT S .
SO/ HER ACTIOIiS IN THE
SHE HAS A TENDENCY TO IGNORE AND
PAST SUGGEST THAT SHE T^iAS
DISREGARD RULES AND
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REGULATIONS DURING
MY I'IIND/ I NEED TO
MY EVALUAT]ON.
THE PUBLIC COMMENT PERIOD, b]HICH ALII]AYS, TN
PI]LL ALL THESE P]ECES TOGETHER WHEN I MAKE
SURE.
OKAY, AND SO YOU KNEW WHO SHE WAS BECAUSE SHli HAD
PREVIOUSLYCOMEToTHESEMEET]}IGSBEEORE,ANDSHEHADACTUALT.Y
VO]CED OPPOSITION TO CERTAIN POSIT]ONS YOU U]ERE TAKING. IS THAT
CORRECT ?
A
THAT SHE
O
1 BELIEVE ]T IS. YES.
OKAY .
DO YOU KIIOVi WHICH ISSUES THOSE WERE?
NOT OEE THE TOP OT MY HEAD. IT WAS SOME TIIiE AGO
COME -_ SHE CAME AND SPOKE.
OKAY .
IILL RIGHT. AND HAVE YOU EVER HAD TO HAVE ANYBODY
REMOVED FROM ONE OF THESE SUCH MEETINGS?
I ' I"1 SORRY ?
HAVE YOU EVEF, HAD TO HAVE AIiYBODY REIV]OVED PHYSICALLY
.F- THF-qtr MtrtrT'T\]CC?
YESI SIR.
HO!{ MANY T]MES, YOU THINK?
I DO}',] ' T RECALL .
15 IT A BUNCH?
. DOI]/ T trECA'L. :-P.
PEOPLE _- PEOPLE GOII,IG OVER THE TIME LIMITS/ REALLY
PHYS ICALLY
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EROIV] ONE
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-_ NOTHING REALLY TOO
EVERY M]]ET ING, DOESN, T
A WE COULD GO
Q WELL, WOULD
IN EVERY MEET ING?
REMARKABLE, IS IT? HAPPEI\]S PRETTY I'TUCH
IT?
BACK AND LOOK, SIR.
YOU SAY ]T HAPPENS AT LEAST THREE TIMES
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] DON' T _.
NOT OI'']LY THE PUBLIC, BUT ALSO THE COMMI SSIONERS
THEMSET,VES ?
SIR, I DON'T KEEP TRACK OE THAT.
WELL, D]D YOU KEEP TRACK IF YOU,VE EVER HAD TO HAVE
SUSAN I'{CCOY REMOVED FROM ONE OF THESE MEETlNGS?
A I DON,T BELIEVE WE D]D.
Q OKAY.
A I DON'T KNOW EOR CERTA]N IE I -_ ] DON'T RECALL THAT
I DI D . I DON, T KI.]OW I E ANYOI.iE ELSE HAS .
Q ALL RIGHT.
HAS SIIE EVER SHOh]N UP AT AT]Y OE THESE Mtr. TINGS AND
DONE ANYTHING WHERE YOU HAD TO GET LAW ENTORCEMENT INVOLVED TO
EITHER HAVE HER ARRESTED OR TO HAVE HER REMOVED?
NO, S1R.
ALL R]GHT.
SO SHtr INDICATtrS THAT SHE' D BE
LEADERSHIP, TRUST/ ]NTEGRITY, AND SIMILAR
THOSE WHO SERVE THE PUBLIC INTEREST?
SPEAKfNG ABOUT
VALUES DES IB.E D BY
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VIRTUES, YES.
Vl RTUE S .
ALL RIGHT / SO ARE THOSE THINGS THAT YOU I'^JOUI'D
SUBSCRIBE TO, LEADERSHIP, TRUST, INTEGRITY, AND SIMILAR
VIRTUES? DO YOU SUBSCR]BE TO THOSE V]RTUES?
I"]S. JACKSON I,IT1 GO]NG TO OB.TECT TO THE RELEVAI]CE OE
A
a
THE WITNESS
MS. JACKSON
THE WI T}]ES S
vtrau T,M --
_- QUESTION.
-_ CONFUSED TOO.
(BY MR. KILGORE) DO YOU AGREE WITH THAT, DO YOU
THINK LEADERSHIP' S IMPORTANT ?
THE COURT: THE OBJECTION, S AS TO RELEVANCE. T,,]HAT, S
THE RELEVANCE?
HE'
IS
MR. KILGOF.E: I,"JELL, HE tdANTS TO DISCUSS THE EACT TH.qT
S SOMEHOW TERRIFIED BY TH]S. U]HAT I NEED TO EIND OUT
WHY?
MS.
MR.
JA^(SON: IHAT WOUI D --
KILGORE: IF HE DOESN. T BELIEVE IN LEADERSHIP.
]NTEGRITY/ I THII.,]K THAT K]ND oE AIiSI/iEt].S THE
ITSELF.
TRUST AND
QUEST ION
I{S. JACKSON: YOUR HONOR, THAT WOULD BE ASKED AIJD
ANSI]ERED. THE WITNESS TESTIFTED THAT THE TDEA THAT THE
DEEENDANT IS CONTACTII{G HIM IS -- IS EI\IOUGH, BASED ON THE
PREVIOUS H]STORY THAT THE ]DEA THE DEEENDANT IS CONTACT]NG
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HIM, IS ENOUGH TO CAUSE CONCERN.
THE COURT: I THINK ]T, S BEEN ASKED AI'JD ANShTERED.
MR. KILGORE: ALL RIGHT.
Q (BY MR. KILGORE) AND ]T ENDS WITH, 1 ALSO -- I'LL
ALSO READ POETRY IN KIND, KINDEST REGARDS, SUSAI'] MCCOY '
AND CERTAINLY A EELLOW LIKE YOU, A POLITICIAN. BUT
YOU, RE NOT AERAID OF POETRY, ARE YOU?
A DEPENDS ON THE CONTEXT, SIR.
Q ALL RIGI]T.
SO ViHAT [,JAS THE I,AST COI4MUNICATION THAT YOU HAD EROM
HER?
A
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WISHING YOU A PEACEEUL DAY, CHA]RMAN LEE.
ALL RIGHT.
YOU WEREII'T THREATEN BY __
] 1'OOK IT TO BE -_
_ _ THAT / I,{ERE YOU ?
I TOOK 1T TO BE TONGUE AND CHEEK, SIR.
WELL, LET. S ASSUME IT b]AS TOI']GUE AND CHEEK; SHE
YOU TO CONTACT MICHAEL PARIS ]N THAT COMMUNICATIO\I.
NO, S]R.
SHE IN NO WAY SUGGESTED THAT YOU OUGHT TO BE
M]CHAEL PARIS IN THAT -_ THAT COMMUI]TCATION, DID
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DlDN'T ASK
DID 5HE ?
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CONTACT lNG
SHE?
I THINK I.i}IAT T STATED/ S]R, TS THAT OVER THE COURSE
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OT TTIqE, THROUGH THE DIEEERENT EVENTS, I CAME TO THE CONCLUS ION
OKAY .
THAT I? WAS BEST TO SHAP.E THE TEXT VJ]TH MR. PARIS BECAUSE SHE
TALKED AND SPOKE TO BEING SiTUATED BACK INTO HER HOME, WHICH IS
TJEAR HIS HOME, AND ]'M AIdARE OF THE EACT THAT THERE'S A
RESTRAINING ORDER ABOUT HER DO]NG SO, SO/ i EELT, BASED OI,] THE
EVEI]TS LEADING UP TO THESE TEXTS, THE ACCUMULATlVE EFEECT OT
ALL THOSE, IS WHAT RAISED I,{Y CONCERI.], SiR.
BOTTOM LINE IS,
YOUR OWN, NOT BECAUSE SHE
AND CONTACT I,f ICHAEL PARIS ?
A
THIS IS AN ACTION ?HAT YOU TOOK ON
SUGGESTED YOU NEED TO GO OUT THERE
A
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PREV]OUSLY
I DON'T THINK -_ YEAH,
OKAY.
AiL RIGHT/ SO I JUST GOT A
YES/ SIR.
YOU MEXIT I OI{ THE EACT ,I,HAT
IN THE PAST ABOUT BEIIJG A
IT WAS A POTEI.JTIAL, SIR.
POTENT I./iL WITNES S ?
YES, SIR.
ALL RIGHT.
] AGREE I4]TH THAT STATEMENT
FEW MORE THINGS EOR YOU
YOU HAD SPOKEN
I"JITNESS II,J THE
WITH COUNSEL
CASE ?
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AND WAS THAT CONVERSATIOI,I THE SAME
THtr TE}1PORARY - r.{tr HAD THE PROTECTM ORDER
COUNSEL AND MR. PARISI LAVJYER CAME UP TO 1OO
WITH YOU THAT DAY AT LIJNCH TIME?
DAY THAT
H EARI NG /
CHE ROKEE
I/E HAD
wH trN
TT] I,1tr E 'F
sAi-iHAr : r'M Nor suRE r FOLLOW YOUR QUEST I O}J
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WITNESS
ALL RIGHT.
!,,]HEN WAS IT THAT YOU S POKE
IN THE CASE?
I DON'T RECALL.
OKAY .
t\rAS I T To DAY ?
},] O , NOT UNT IL WE GOT HERE .
TO COUNSEL AECUT BE I}:]G A
WE SAID HELLO TO EACHA
OTHEP,.
O
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THE CASE?
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!.JAS IT BEEORE TODAY?
WAS WHAT EEEORE TODAY?
[]HEN COUI\ISEL SPOKE TO YOU ABOUT BEING A WITNESS IN
YES.
WHEN WAS THAT ?
I DON'T RECALL, S]R.
OKAY.
DO YOU RECALL IF ]T WAS LAST WEEK?
NO. IT WAS NOT.
OKAY.
WAS IT LAST MONTH?
I DON' T RECALL, SIR.
ALL RIGHT.
I,{ELL, SUSAN MCCOY CERTAINLY WASNI T AT THAT MEETING,
WAS SHE ?
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NO, SIR.
OKAY .
YOU AGREE SUSAN MCCOY WOULDN, T HAVE ANY WAY OE
KNOWING WHATEVER IT IS THAT YOU TALKED ABCJUT WITH COUNSEL?
A I DON' T Kl'lOW rllHAT SHE KNOWS .
Q YOU GOT MESSAGES FROM THE T!,dENTY_SIXTII OE EEBRUARY TO
TH FIRST OF MARCH, RIGHT?
A YES, SIR.
V IlLLJ r\-L lrIr .L.
AND SO _- AND YOU'VE ALREADY TOLD US THAT YOU __ YOU
CONTACTED MR. PAR]S ABOUT IT, EVEI.I THOUGH SHE -- SHE DiDi]i, T ASK
YOU TO. DID YOU __ DID YOI] CONTACT ANYBODY ELSE ABOUT IT,
CTHER THAN THE -- OTHER THAt\l THE COI'{MISSIOIJER -- I MEAI'I MR.
HF,ATON ?
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THE COUNTY MANAGEP., AND THE SHERIEE/ S OFFICE.
WHAT ABOUT SAM OLEN S ?
I DID NOT .
WHAT ABOUT JAMES TOUCHTON?
I DID NOT.
OKAY.
MR. KILGORE: ] THINK THAT, S ALL I,VE GoT, JUDGE.
MS. "TACKSON: JUST A FEI,,J QUESTIONS ONt REDIF.ECT.
R,ED]RECT EXAM]NATlON
MS. JACKSON:
Q NOW, YOU'RE CONSTANTLY CONTACTED __ ARE YOU
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A
A
COTISTANTIV CONTACTED BY YOUR CITIZENS?
A VE.Q MA, AM
1S IT UNUSUAL TO RECEIVE TEXT MESSAGES AT SIX O'CLOCK
IN THE MORN]NG?
VERY UNUSUAL.A
ON YOUR PERSONAL CELL PHONE?
YES, MA,AM; YEAH, IT,S VERY UNUSUAL.
1S IT UNUSUAL EOR YOU TO RECEIVE MESSAGES FROM YOUR
ClTIZENS ON SUNDAY MORNINGS?
VERY UNUSUAL.
Q AD WHAT IS THE IMPACT TO YOU OE ALL OE A SUDDEN
RECEIVING THESE TEXT MESSAGES EROM SUSAN MCCOY. GIVEN WHAT YCU
KNOW ABOUT THE HISTORY?
A GIVEN THE HI STORY,
WITH MY FAMII,Y AND MYSELF AS
AND AS SUCH WE HAVE A HIGHER
CONCERN EOR OUR WELEARE.
Q AND IS IT NATURAL TOR
FOR CONCERN. EOR YOU TO CONTACT
IT/S __ IT'S CAUSED GREAT CONCERN
TO THE F'INIAL INTENT OE'MS. MCCOY,
-- HIGHER AWARENESS, A HIGHER
YOU TO, IE THERE IS A REASON
SOMEONE ?
A ABSOLUTELY.
Q AND SO WHEN YOU CONTACTED
TEXT MESSAGES. WHY DID YOU DO THAT?
A I HAD CONCERN FOR H]M AND
HISTORY THAT I WAS AWARE OE. AND THE
KNOWING THAT SOME TSSUES HADN/ T BEEN
M]CHAEL PARIS ABOUT THESE
HIS FAMILY BECAUSE OF THE
UNCERTA]NTY AS TO THE __
RESOLVED YET AS IT RELATES
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TO THE PRIOR INC I DENT S
YOU
MS. JACKSON
THE COURT:
THE W]TNESS
THE COURT:
MR. Kl LGORE
THE COUP.T:
THE WI TNES S
IlS. JACKSON
THE COURT:
NOTHING FURTHER OF
ALL RIGHT, SIR, YOU
THIS !{TTNESS.
CAN STEP DOhlN. THANK
THI\TIK YOU. SHOULD I LEAVE THE ROOM?
IS THI S IdIT}]ESS BE FREE TO GO?
] DON'T HAVE ANYTHII.IG ELSE.
OKAY, YOU/ RE FREE TO GO. SIP,.
THAI.]K YOU.
THE STATE CALLS MICHAEL PARIS.
SOMEBODY GO GET HINI.
MICHAEL EMBRY PARI S,
SWOF.I.I, WAS EXAMINED AND TEST]EIED ASHAVIN]G BEEN EIRST DULY
EOLLOWS:
BY MS. JACKSON:
A
I DID.
DIRi'CT EXAMIIJATiON
STATE YOUR \TAME FOR THE RECORD.
M]CHAEL EMBRY PARIS.
Q AND DID YOU PREVIOUSLY TEST]EY I},] A PF.OTECTIVE ORDER
HEARING REGARDING THE DEEENDANT, SIJSAN MCCOY?
Q AI']D DID YOU HAVE THE OCCAS]ON TO HAVE A CONVERSA'IION
WITH CHAf PM.AN TIM LEE REGARDING CE]iTAIN TEXT MESSAGES?
A 1ES, I DID.
Q CAN YOU TELL THE COURT WHAT YOU KNOW ABOUT THE TEXT
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A WEIL, idHAT ] KI',] OI,{ THAT __ ] BELIEVE SL]ON AETER 1'1S.
MCCOY HAD __ HAD BEEN IN A P]ENTAL HEALTH EACULTY THAT SHE BEGAN
TO TEXT T]M ].EE, AND __ SEVERAL TEXT }IESSAGES, ESPECIALLY ONE
OE THEM THAT I UNDERSTOOD REEERRED TO HER SAYING THAT SHE WAS
GOlNG TO COME TO ALL COUNTY COMM]SSION MEETINGS AND ATLANTA
REGlONAL COMMlSSION MEETINGS, AND THAT REALLY CONCERNED ME
BECAUSE PART OT MY JOB IN MY EMPLOYMEJI{T IS THAT ] ATTEND THOSE
MEET]NGS ON A REGULAR BASIS.
Q A\ID WOULD IT __ WOULD IT BE NATURAL FOR YOU TO
COMMUNICATE WITH MR. LEE AI]OUT THIS PARTICULAR ISSUE?
MESSAGES, AND T,,iHAT YOUR RESPONSE WAS?
IT WOULD BE.
AND WHY WAS 1T SO CONCERNING TO YOL] THAT HE HAD
GOTTEN' THESE TEXT MESSAGES ?
WELL, IT'S CONCERNING IS _- ]S THAT I FELT THAT, YOU
KNOW, I _- I EELT __ YOU KI.IOW, CONCERNED EOR lIY OWN SAEETY,
AETER EVERYTHING THAT HAS ALREADY HAPPENED WITH ME AND MY
FAMILY REGARDI}'.]G MS. MCCOY. THE E}4AILS THAT SHE SENT US OVER
TIME, THE FIFTY-SEVEN EMAII,S. AND HAI] BEEN HARASSING US/ AND I
THOUGHT THIS WAS __ TO ME 'fHIS WAS ALMOST AN IN]DIRECT WAY OE
GETTING TO ME, SII.ICE SHE CAIJ'T TALK TO ME DIRECTLY, OR
SHOULDN'T BE CONTACTING ME DIRECTLY.
AND HOI^] FAR AWAY I S IT THAT YOU LIVE FRoM MRS . ]"ICCoY?
IT'S h]ITH]N -- IT'S AROUND THE CORNER, JUST A EEW
HOUSES AWAY.
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MS. JACKSON: NOTHING EURTHER OF THlS WITNESS.
TIIE COURT; CP.OSS EXAMINATION.
CROSS EXAMINAT I ON
BY MR. KILGORE:
Q OKAY, NIR. PARIS, THE LAST TII"]E THAT YOU HAD RECEIVED
ANY CONTACT EROM MS. MCCOY, ISN'T IT TRUE THAT WAS NOVEMBER
THIRTEENTH, OT TWO THOUSAND FIETEEN?
THAT IS RIGHT.
Q SO YOU DIDN'T RECE]VE ANY THE REST OF NOVEMBER, OR
DECEI4BEB, THE REST OF TI,{O THOUSA}ID F]TTEEN AT ALL, CORRECT?
A THAT IS CORRECT.
Q AND T },] .TANUARY YOU DIDN'T RECEIVE ANY COMMUNICATION
EROM HER WHATSOEVEF., DID YOU?
A NO, S]R. 1 DID NOT.
Q I WA}JT TO MAKE SURE ] __ b]E'RE TALKING ABOUT Tl]E SAME
THINC.
A THAT'S RIGHT.
Q WHAT ABOUT PHOI,IE CALLS? DID SHE __ DID SHE CALL YOU?
A SHE DI D NOT CALL I.{E .
Q OKAY.
WHAT ABOUT COI.IING UP TO YOUR HOUSE, DID SHE COI,{E TO
YOUR HOUSE AT ALL DURING THAT __ THOSE COUPLE OE MONTHS?
A NOT WHILE I WAS THERE.
Q OKAY.
DID SHE TEXT YOU?
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SHE DID NOT TEXT
ALL RIGHT.
DID SHE SEND YOU
NO, S IR, SHE DID
WHAT ABOUT MAIL,
NO, SIR.
OKAY.
DID SHE SEND __
UP TO YOUR OEEICE
OR DECEMBER/ OR
NO, SHE D]D NOT.
OKAY .
AND THEN JANUARY THE NINETEENTH,
__ YOU TOLD THE MAGISTRATE COURT
NOT EEEL SAFE UNLESS THAT WOMAN,
OE GEORGIA, NO CR]M]NAL RECORD,
SHE'S LIVED IN HER ADULT L]EE.
ME.
ANY EMAILS ?
NOT.
REGULAR MAIL?
DID SHE SEND AN EMISSARY TO COME UP
AND HAVE CONVERSATION W]TH YOU IN
JANUARY ?
AND COME
NOVEMBER,
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YOU TOLD
YOU WOULD
STATE BAR
HOME THAT
TOLD TH]S
A
ALL TH] S
O
YOU CAME IN HERE AND
THAT YOU WERE NOT _-
A MEMBER OE THE
WAS REMOVED FROM HER
PRETTY MUCH !^IHAT YOU
S IXTEEN I
FORM, HAS
MAGISTRATE, RI GHT ?
I FILED THAT IN THE EIRST OF JANUARY, SHORTLY AFTER
HAD OCCURRED.
ALL RIGHT.
ALL RIGHT, SINCE JANUARY THE NINETEENTH, TWO THOUSAND
MS. MCCOY HASN'T CONTACTED YOU IN ANY WAY, SHAPEI OI1
SHE?
NOT D]RECTLY.A
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Q SHE HAS}J'T CALLED YOU, SHE HASN'T COIIE TO YOUR HOME,
SHE HASN'T EMAILED YOU. SHE HASN'T TEXTED YOU, SHE HASN'T SEI]T
AI'] EMISSARY TO YOUR OFEICE TO HAVE A CONVERSATION WITH YOU, SHE
HASN'T SENT YOU ANY MAIL, SHE HASN'T CONTACTED YOU. ISN'T THAT
TF.UE ?
A YES, S]R.
Q YOU BECAME A!^IARE THAT MR. LEE, HOWEVER, HAD RECEIVED
SOME MESSAGES, CORRECT ?
A TI]AT IS RIGHT.
Q A\]D DID HE SHOb] YOU THOSE?
A YES, HE D]D,
OKAY.
DID HE SHOW YOU ACTUALLY ON H]S PHONE?
A HE SHOI,{ED _- HE -- HE TAI,KED TO ME ABOUT THEM, AND
SHOWED THEM TO ME, YES.
Q OKAY.
Al.lD YOU CERTAINLY AGREE THAT NOI/iHERE IN ANy OF THOSE
MESSAGES DOES HE DIRECT -- DOES SHE DIRECT H]M TO HAVE _- TO
CONTACT YOU?
A SAY THAT AGAIN.
Q NOIIE OF THOSE MESSAGES MENTION YOU AT ALL, DO THEY?
A THEY DO NOT MENTION ME.
Q NONtr OE THOSE MENTIONED __ NONE OE TIIOSE N,]ESSAGES
DIRECT TIM LEE TO CALL YOU, OR TEXT YOU/ OR EMAIL YOU, OR HAVE
A CONVERSAT]ON AT A],L, DID THEY?
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THAT -_ THAT, S CORRECT.
ALl- R] GI]T .
AND, ]N EACT, WHAT !^]E,RE TALKING ABOUT HF,RE IS
EXACTLY !,^JHAT I/iE V,JERE TALKII']G IN THE PROTECT IVE HEARING . I F MS .
MCCOYDOESN,TGETToGoToTHOSECOMM]SSIONMEETINGS,THEI..]HER
POL]T]CAL VO]CE ]S SHUT DOWN ON ANY ISSUE THAT _- ON ANY ISSUE
AT ALL, ISN,T THAT CORRECT?
A
A WELL, I DON, T KNOVJ.
WE GOT THAT, BUT IE
I'M LOOKING AFTER MY R]GHTS.
SHE CAN' T BE THERE , SHE CAI'J' T
TIM LEE ARE TRYIN]G TO PUSHOPPOSE ANYTIIING THAT YOU AI'I D
EORWARD, ISN'T T1IAT TRUE?
A I DON'T KNOW THAT THAT'S TRUE AT ALL.
Q WELL, ]E SHE CAN'T BE THERE, SHE CANIT
UP TO THAT MICROPHONE AND SAY ANYTHIIJG, CAN SHE?
A ]F SHE'S NOT THERE, SHE CAN'T SPEAK.
LETTERS, SHE CAN DO ALL K]NDS OE THIIIGS. SHE'S
Q SURE.
SHEIS A CITIZEN, BUT YOU DON'T WA}JT
RIGHT TO BE ABLE TO WALK UP TO THAT M]CROPHONE
COMMISSION MEETINGS, DO YOU ?
VERY T^]ELL VJALK
SHE CAII l,,JF.I TE
A C]TIZEI.].
HER
AT
TO HAVE THE
THOSE
I'.1S. JACKSO\I: YOUR HONOR, I't'{ GOING TO OBJECT TO THE
RELEVANCE. THE WITNESS HAS ALREADY TESTIEIED THAT HE JUST
DOESN/ T WA}.] T TO HAVE ANY CONTACT WITH THE DEFENDAI.IT. HE/ S
NOT THE ARBITRATOR OE THE DEEENDANT' S CONSTITUTIONAL E]RST
AMENDMENT RIGHTS, AND THAT'S NOT WHAT THIS IS ABOUT.
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THE COURT: RESPONSE, MR. MADDOX?
MR. KILGORE: WELL, I WOULD SUGGEST TO THE COURT -_
THE COURT: MR. KILLGORE, I,M SORRY.
MR. KILGORE: THAT'S OKAY; COMMON -- COMMON MISTAKE.
I WOULD SUGGEST THAT HE IS THE CENTRAL FIGURE IN THE
DENIAL OF HER FIRST AMENDMENT RIGHTS, AND HE OUGHT TO BE
CROSS EXAMINED ON THAT.
THE COURT: I DISAGREE. ] THINK IT GOES BEYOND THE
RELEVANCE OE THIS.
MR. KILGORE: OKAY, THANK YOU.
THE COURT: REDIRECT?
MS. JACKSON: NO.
THE COURT: ALL RIGHT, S]R, YOU CAN STEP DOWN; THANK
YOU.
BY MS. JACKSON:
PAUL CAMARILLO,
HAVING BEEN EIRST DULY SWORN, WAS EXAMINED AND TESTIF]ED AS
FOLLOWS :
MS. JACKSON: THE STATE CALLS PAUL CAMAR]LLO.
DIRECT EXAMINATION
Q STATE YOUR NAME FOR THE RECORD.
A PAUL CAMARILLO.
Q HOW ARE YOU EMPLOYED?
A WITH THE COBB COUNT DA'S OEEICE.
Q AND WHAT IS YOUR ASS]GNMENT?
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A I'M AN ASSISTANT D]STR]CT ATTORNEY, AND I'M ASSIGNED
TO JUDGE GRUBB' S COURTROOM.
Q AND WERE YOU THE DUTY DA ON OR ABOUT FEBRUARY
TI,{ENTY_N]NTH __
A ] WAS.
N __ r)tr THTq YFAP?\l v'
A I I,JAS .
Q AND WHAT DAY OE THE TI]EEK WAS THAT?
A THAT I'M NOT SURE. I'M NOT POSITIVE.
Q WOULD IT HAVE _- WOULD IT HAVE BEEN A MONDAY?
A PROBABLY.
Q OKAY.
AND DID YOU HAVE THE OCCASION TO ENCOUNTER THE
DEEENDANT, SUSAN MCCOY?
A I DID.
Q CAN YOU TELL THE COURT WHAT HAPPENED DURING THAT
ENCOUNTER?
A SURE. SC I'M NOT SURE, YOUR HONOR, ]E YOU KNOW ALL
WHAT THE DUTY DA'S DO/ BUT WE HANDLE ALL THE __ THE CALLS AND
THE QUESTIONS THAT COME FROM PEOPLE THAT SHOW UP TO THE LOBBY.
SO, THAT DAY I GOT A CALL TO MY OEEICE THAT THERE WAS A LOCAL
ATTORNEY WHO HAD A LEGAL QUESTION THAT NEEDED TO BE ANSWERED.
SOI ] WENT UP TO THE LOBBY AND I SAW MS. MCCOY IItrRtr/ AND I
ASKED HER, YOU KNOW, HOW CAN I HELP YOU?
AND SHE ASKED IF THERE I1]AS A PLACE WHERE WE COULD
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TALK, BECAUSE THERE WAS SOME PEOPLE AROUND.
SO I SAID, SURE, I{E CAN GO TO MY OEE'ICE. SO, WE
WENT DOWN TO MY OEE]CE, AND I INTRODUCED MYSELF, SHE INTRODUCED
HERSELE, AND WE _- WE JUST EXCHANGED PLEASANTRIES.
AND THEN SHE SAID SHE HAD __ SHE WAS ACTUALLY LOOKING
EOR VIC, TO TALK TO V]C THAT DAY, VIC REYNOLDS, THE DISTRICT
ATTORNEY, BECAUSE SHE KNEW HIM, AND SHE TRUSTED HIM, AND __ AND
__ BUT I SA]D, WELL, MAYBE 1 CAN HELP YOU W]TH WHAT YOU'RE __
WHAT YOU'RE ASKING FOR, YOU KNOW, WHAT, S YOUR QUEST]ON?
AND SHE SAID THAT SHE HAD TO START WITH THE __ SHE
HAD TO GO BACK IN TIME TO EXPLAIN KIND OF WHERE SHE WAS AT.
SO. SHE TOLD ME ABOUT AN ARSON HAD OCCURRED AT HER HOUSE, IN
HER ERONT YARD/ AND THAT IT WAS UNSOLVEDI AND THAT BECAUSE OE
THAT/ SHE -- SHE STARTED SUEEERING FROM SORT OF -- SHE DIDN/T
EXPLAIN EXACTLY WHAT IT WAS, BUT SHE SA]D THAT SHE __ SHE
!^JASN'T THINKING CORRECTLY, AND THAT SHE HAD SENT SOME EMAILS
THAT SHE DOESN'T REMEMBER SENDING, AND THAT BECAUSE OT THAT,
THERE WAS A TPO TAKEN OUT AGA]NST HER.
SO AT THAT POINT I STTLL DIDN'T KNOW, OTHER THAN THAT
IT WAS SOME SORT OF C]VIL TPO, IT SOUNDED LIKE TO ME, SO J
ASKED HER, OKAY, WELL, WHAT KIND OE, YOU KNOW. PAPERWORK DO YOU
HAVE? WHAT DOES IT SAY YOU CAN' T DO? WHAT ARE YOU TRYING TO.
YOU KNOW, GET HAPPEN. SHE WANTED A COMMISSION MODIFIED ON IT.
SO, SHE HAN]fED MLJ A P]ECE OE PAPER, AND ]T WAS __ IT LOOKED
L]KE SOME BOND CONDITIONS EROM THE COBB COUNTY MACISTRATE
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COURT. SO, ] SA[] HER NAME AT THE TOP, AND ] REALIZED AT THAT
POII\]T, OH, OH, THIS IS THE DEFENDANT, NOT -- NOT JUST -- I
MEAN, SHE MAY BE AN ATTORNEY, I DON'T KNOW/ BUT SHE WAS ALSO
THE DEI'ENDANT IN A CASE.
SO I SA]D, HANG TIGHT, LET ME LOOK SOMETHING UP FEAL
QU]CK. SO, I LOOKED UP HER NAME IN MY COMPUTER SYSTEM, AND I
SAI{ THAT ]T !.IAS A CASE THAT WE HAD CONFLICTED OEE, AND THAT THE
PROSECUTOR ATTORNEY'S COUNSEL HAD TAKEI{ OVER WITH THE
PROSECUT ION .
SO, I SAID, YOU KNOW. ] CAN'T REALLY HELP YOU ViITH
ANY COIIDITIONS, BECAUSE __ BECAUSE WE'RE NOT ON THE CASE
ANYMORE. WE DOl.]'T HAVE AI.IY AUTHOR]TY TO DO A}J]]THING. EVEN IE
I WANTED TO HELP YOU. WH]CH I WOULD I,OVE TO TRY TO HELP YOU.
BUT i CAN,T, BECAUSE WE DOI\],T HAVE AUTHOR]TY, BUT I WOULD REEER
THAT TO THE __ TO THE __ THE ATTORNEY THROUGH THE STATE THAT'S
HANDLING THE CASE.
AND SO SHE SAID SHE UNDERSTOOD, AND YOU KNOW, WE JUST
CONTII']UED JUST TALKTNG ABOL'T, YOU KNOW, JUST REALLY RAN DOIV]
STUE'T. I WAS, AT THAT PO]NT __ OR ] SAW THAT THE CHARGE WAS
AGGRAVATED STALKING, AND SO IT CONCERNED ME A LITTLE BIT. BUT ]
DJDN'T __ YOU I{NOIi, ] JUST __ I JUST KEPT TALKING ABOLIT JUST
NORMAL STUEE, AND __ AND SHE !!AS TALKING ABOUT HER CH]LDREN,
AND THNT' S WIIY SIIE WANTED TO GO AND GET THIS CONDITION
MODI Fl ED.
SO SHE __ AT THAT POINT WHILE SHE WAS TALKING ABOUT
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HER CHILDREN/ SHE
SHE REALLY I,iANTED
KIDS,A__AWIEE
IN MY OTEICE.
STARTED TO BREAK DOWN CRYING, AND SHE SAID
TO GET BACK HOME TO BE A _- A MOTHER TO HER
TO HER __ HER HUSBAI']D, AND THAT' S I'iHY SHE WAS
Q LET ME ASK YOU THIS __
MR. KILGORE: HOLD ON.
GETTING TO THE PART THAT _-
TO HEAR ABOUT, AND SHE CUTS
THAT HE BE ALLOWED TO EIN]SH
THE COURT; ALL R l GHT,
EINISH.
I, M GOING TO OBJECT. WE' RE
THAT WE THINK THE COUF.T NEEDS
HIN1 OEE. I, I"1 GOING TO ASK
YOU CAN __ I ' LL LET YOI-I
THE WITNESS: SHE STARTED TO BECOMING VERY EMOTIONAL,
AND SHE, AT THAT POINT, K]ND OE STARTED _- I TH]NK SHE
STARTED KIND OE GOING BACK ]NTO THlS __ THIS OR]GINAL
STORY, AND SHE WAS K]ND OF JUI'IPING EROM -. TROM HER, YOU
KI.IOW, WANTIIIG TO BE A MOTHER, TO THE CASE, TO THIS AI.JD
THAT, AND SHE WAS -- YOU KNOW, I __ SHE WAS __ SHE WAS
VERY EMOTIONAL. THAT'S THE BEST 1 CA}I __ I CAN DESCRIBE
IT.
Q (BY MS. JACKSON) DlD SHE APPEAR TO BE RAMBLING?
A SHE __ IN SORT OE A METHODICAL KIND CE WAY. IT WAS
__ UP UNTIL THAT POINT HER __ HER SPEECH, WHEN SHE WAS TALKING,
WAS KIND OE VERY DELIBERATE. IT WAS __ IT WAS I{IND OF AT A
SLOWER PACE THAN WHAT I WOULD CONSIDER JUST NORF1AL SPEAKING,
BUT T DON'T KNOW HtrR, SO 1T COULD MAYBE HtrR NORMAL I'AY Otr
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SPEAKING, I DON'T KNO!{, BUT IT WAS VERY -_ IT
METHODICAL, AI'JD THE}.J WHEN SHE BROKE DOWII SHE
GOING FASTER EROM TOPIC TO TOPIC.
Q DID YOU TALK TO HER ABOIJT THE EACT
REPRESENTED?
A ] DID _-
Q BY COUNSEL?
r,IAS VERY
STARTED K]ND OE
THAT SHE II]AS
A YES. AT THAT POINT -- AT THAT PO]NT I DID, AND T"iHEN
I _- WHEN I BROUGHT UP THE FACT THAT SHE WAS REPRESENTED/ THAT
SHE NEEDS TO tsE GOING THROUGH HER ATTORI.IEY TO BE DOII.IG
EVERYTHING I}i THE FUTURE TO TI.iE PROCESS, SHE SA]D TH.AT -SHE HAD
JUST GOTTEN OIJT OE RIDGEVIEW, AND AT THAT POINT, IN MY MIND,
AND FROM EXPEF.IENCE WITH THAT'S A MENTAL HEALTHCARE EAC]LITY,
SHE __ .qHE SA]D, THAT'S HOVi ] ENDED UP AT RIDGEV]EW IN THE
FIRST PLACE, WAS BECAUSE OF MY ATTORNEYS.
SO. I SAID, WELL, BY __ BY LAW, ETH]CALLY, I HAVE TO
TELL THEM EXACTLY WHAT YOU SAID, AND I HAVE TO TELL I"{Y BOSS
EXACTLY WHAT YOU SAID. I HAVE TO TELi THE PROSECUTOF. EXACTLI
WHAT WAS SAID, BECAUSE YOU'RE A REPRESENTED PERSON. AND I
CAN'T, YOU KNOW/ TALK ABOUT THE CASE, AIID WHEN ] TOUND OUT SI{E
WAS REPRESENTED, ] ACTUALLY SAID. WE'RE NOT GOING TO TALK ABOUT
THE CASE AT ALL ANY},IORE.
AI.] D THtrl.I SHE SATD, YOU KNOW/ I KNOI' TIItrY THEY
THINK I'M CRAZY, BUT I'M NOT. SHE SA]D. ]'M THINKING SO
CLEARLY RIGHT NOW, THAT I DON'T __ I DON'T NEED ANYMORE
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-;, - -rMEDICATION, I,M NOT M-DICATION' BECAUSE SHE'S -_ BECAUSE I,M
SHE SAID IN HER WORDS, I'M THINKING SO CLEARLY RIGHT NOW'
MS. JACKSON: NOTHING EURTHER FROM THIS T,JITNESS.
THE COURT: CROSS EXAMINAT ION
MR. KILGORE: OKAY.
CROSS EXAMINATION
BY MR. K]LGORE:
Q PAUL, SHE CAME IN __ DO YOU REMtrMBER WHAT DAY iT WAS?
A ] TRY TO DO DUTY DA'S ON MONDAYS OR FRIDAYS, SO IT
WAS EITHER A FR]DAY OR MONDAY. I REMEMBER IT WAS __ IT WAS THE
TWENTY_NINTH, BECAUSE IT WAS NOT A NORMAL EEBRUARY.
Q EEBRUARY TWENTY_NINTH?
A YEAH, IT WAS A MONDAY.
Q OKAY.
A MONDAY MORNING.
Q DID SHE _- EXCUSE ME. D]D SHE TELL YOU THAT YOU
NEEDED TO CONTACT MICHAEL PARIS EOR HER, AND TO TELL M]CHAEL
PAR]S TO LET HER BACK IN HER HOME?
A I DON'T __ I DON'T KNOW WHO MICHAEL PARIS/ BUT 1__ I
REMEMBER -- IS THAT A WITNESS, OR SOME __ SOMEBODY? I DON'T
REMEMBER HER SAYING THE __ OTHER THAN IE IT b]AS PART OE HEF.
ORIGINAL STORY THAT SHE TOLD, BUT I DON'T REMEMBER HER ASKING
ME TO CONTACT ANYBODY.
Q OKAY.
A I TOLD HER ] WAS GOING TO CONTACT PEOPLE ON BOTH
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Q D]D SHE TELL YOU THAT EVEN THOUGH THERE HAD BEEN NO
ADDITIONAL CONTACT SIIICE NOVEMBEF,, SHE WAS PUT OUT OE HER HOME
THE THIRD I^]EEK OF JA\]UARY, TWO THOUSAND S]XTEEN?
A SHE TOLD ME SHE I,{AS PUT OUT OF HEB. HOME, AND TH7\T SHE
WANTED THE CONDITIONS CHANGED, BECAUSE SHE WANTED TO GO BACK TO
HER HOME.
SIDES OE HEF. CASE.
A].L RICHT.
SHE APPEARED ]N YOUR OEE]CE AND SHE I^IANTED
HEARD, SHE HAD A},] ISSUE, AND SHE POURED HER HEART OUT
IS THAT A PRETTY FAIR ASSESSMENT OF WHAT HAPPENED?
TO BE
TO YOU,
A SHE WAS VER.]' __ SHE SEEMED \J,ERY D]STRAUGHT AIJD
ELJOTIONAL OVER THE WHOLE THING.
OKAY.
AND DID SHE TELL YOU THAT -_ THAT IT WAS SO TRAUMAT IC
HAD TO BEFOR HER BEII.]G REI'{OVED EROM HER HOME, THAT SHE
COI'IMITTED TO RI DGEVIEW TWO DAYS LATER?
A I DON'T RECALL HER EVER SAYING THAT BEING REMOVED
FROM HER HOME tr{AS WHAT CAUSED HER TO BE PUT IN RIDGEVIEW. BUT I
-_ ALL ] REIVIEMBER ABOUT RIDGEVIEU] WAS THAT SHE HAD .TUST BEEN
RELEASED. I'M I'IOT SURE/ OTHER THAN THAT, AND THE FACT THAT SHE
H.AD MENTIO}IED THAT GOING TO HER ATTORNEYS CAUSED __ HAD CAUSED
I]ER TO GO TO F.IDGEVIEI4 IN THE FIRST trLACE.
UH-HUH (AFFIRMAT" VL/ .
AND BE]NG TN THE D]STR]CT ATTORNEY'S OFFICE, A}iD
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WORK]NG IN THE CRIM]NAL JUSTICE SYSTEI,I, YOU WOULD AGREE THAT
E]THER BY COURT ORDER, OR BY, ] GUESS, COUNSEL AIDED
ASSISTANCE. THE SYSTEM, WE -- WE WANT TO ENCOUF.AGE PEOPLE TO
GET MENTAL HEALTH TREATMENT, IE THEY NEED IT?
A ABSOLUTELY.
Q OKAY.
SO, IN THAT REGARD, THERE'S NOTHING PARTICULARLY
RFIMARKABLE ABOUT THE FACT THAT. HEY, I/iE GOT SOMEBODY ON BOIID,
SPENT A L]TTLE T]ME AT RIDGEVIEW. HAPPEI.]S ALL THE TIME,
DOESN / T IT?
A ALL THE TIME.
Q OliAY.
A YES, SIR.
Q OKAY.
A NO/ SIR.
Q IN EACT, SHE MADE NO THREATS AT ALL AGAINST ANYONE.
DID SHE ?
A}I D THERE/ S REALLY NOTHING UNCOMMON ABOUT THAT, 'U{E
HAVE LOTS OF DEEENDANTS WHO SEEK MENTAL HEALTH TREATMENT,
CORRECT ?
A THAT' S CORRECT.
Q SHE WEPT.
A YEg.
SHE __ AT NO POTNT I}J TTME DID SHE APPEAR THREATE}]]NIG
IN ANY WAY TO YOLI OR ANYBODY IN THE DA'S OFEICE?
<A
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MR. KlLGORE:
THE COURT:
MS. JACKSON:
JACKSON:
OKAY/ THANK YOU.
ANY P,E D] RECT ?
ONE QUESTION.
RED]RECT EXAMINATION
OVER THE
VICTIMS?
DID THE DEFENDANT. AT ANY POINT, EXPRESS ANY CONCERIN
IMPACT THAT HER BEHAVIOR HAS HAD ON ANY OE THESE
A NO. HEP. MAII.I CONCERN WAS -_ WAS GETTING BACK TO HEF.
HO]"IE, ACCOP,DING -- FROM WHAT SHE TOLD ME.
Q IT WAS ALL ABOUT HER?
A YES. I DON'T RENIEMBER HER MENT]ONING ANYTH]NG. OTHER
THAN I REMEMBER HEARING THE] NAME TIM LEE. EVEF.YBODY ELSE SHE
I'IENT1O]'lED I HAD NO RECOLLECTIOI'l Or/ T DIDI\l ' T KNOW hlHO TI]EY
WI]RE .
BY I'1S.
o
PARI S
A
O
A
O
SAM OLENS'
SHE
AND HIS
I'tO.
D]D
NO.
MENTIONED TlM LEE ?
FAMI LY ?
SHE TALK ABOI]T SAI.' OLEl,lS ?
DID SHE TALK ABOUT MICHAEL
DID SHE TALK ABOUT THE TACT THAT SHE HAD COTITACTED
CHILDREN ?
NO.
TAKEN PHOTOGRAPHS OE TTM OLENS' HOUSE?
NC, Sl., -- N,, IvA'arl .
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Q IT WAS Oi'iLY ABOUT HER AND WHAT SHE I'']EEDED AT THAT
TI}lE?
A THAT'S CORRECT.
MS. JACKSON: NOTHING FURTHER.
THE COURT: YOU CAN STEP DOI/,iN.
MR. K]I,GORE: JUDGE, COULD I ASK H]M ONE THING,
PLEASE?
THE COURT: SURE.
N1F.. KILGORE: SOR.RY.
RECORD IS CLEAF., SHO!^J HIM
TllE COURT: OKAY.
RECROS S
JUST -_ JUST TO MAKE SURE THE
A COPY OF THE !^JARRA}JT ?
EXAMINATION
BY MR. K]LGORE:
Q IT SHOULD BE I}J THE F.ILE, BUT JUST
DOES TI]AT LOOK LIKE ONE OE OUR WARRANTS HERE
COURT? TYPICAL FORM WE HAVE?
ACCRAVATE D
FOR
OL]T
THE RECORD,
OF MAGI S TRATE
YES. SIR.
AND I{HAT'S THE I,JARRANT IIUMBER OI] THEF.E?
15-w-10338.
ALL RIGHT.
AIID IS THAT THE WARF.AI]T CHARGING MS. I{CCOY WITH
Q'I-AT 11 T \]''
TT IS.
A],L RIGHT.
CAI.'I -- CAN YOU E'LIP THAT OVER, PLEASE? YOI] SEE ON
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THE PLACE WHERE IT LISTS !"i]TNESSES,
WITNESS LISTED ON THAT I^TARRANT?
A
O
DO YOLI ?
A
BY
OF
CAN YOU TELL US WHO' S A
NO.
llR. KILGORE: ALL RIGHT. THANK YOU
MS. JACKSON: ONE LAST QUESTION.
THE COURT: SURE, GO AHEAD.
FURTHER REDIRECT EXAMINAT]ON
MS. JACKSON:
O ON ANY WARRANTS THAT YOU GUYS DO, DO YOU EVEP SEE ALL
THE WITNESS' I'IAMES ON THOSE WARRAI.ITS ?
A IT' S USUALLY THE LEAD OFEICER, OR I F THERE ] S I.]O
JAMES STRAYHORN.
ANYBOD/ ELSE ?
P. KENNEDY.
OKAY .
YOU DOIJ'T SEE TIM LEE,S NAME ON THEP'E AS A WITNESS,
]NVOLVED. THE LEAD -- THEY USUALLY PUT THE __ IT WOLTLD
PROSECUTOP.. BUT THAT'S REALLY LIKE MAYBE THE LEAD
IN THE CASE, IF IT h]AS A CASE WHERE THERE WAS NO
ASSIGNED AND THEY IAIEI.]T AND GOT THEIR OI,JN WAB.RANT.
HAVE YOU EVER HAD ANY BOND __ AT ANY COURT IN COBB
]N YOUR EXPERIENCE. EVER NOT REPLIED TO A WITNESS JUST
THE]R NAI,IE WASN' T II.] THE WARRP.I.IT ?
NO, THAT' S USUALLY DONE AT THE BOND HEARING WHERE
OFFI CER
BE THE
WITNESS
O!'F1CEF.
O
COUNT ,
BECAUSE
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THEY LIST THEM OUT.
MS. JACKSON:
THE COURT:
rJr.Ai, lnHL J l1!rr.
ALL RIGHT, S]R, YOU CA}''] STEP DOWN; THAI',]K
YOU.
THE I,{ITNESS: THANK YOU, SIR.
THE COURT: WHO, S NEXT?
]"]S. JACKSON: THE STATE CALLS BETSY MANSTON
THE COURT: tsETSY tiANSTAll .
BETSY MANSTON.
HAV]NG BEEN F]RST DULY SWORN, WAS EXAMINED AND TESTIF'IED AS
EOLLOWS:
D I RI]CT EXAMINATIOI']
BY I"1S. .lACKSOI.]:
Q STATE YOUR NA}1E FOR THE RECORD.
A BETSY MANSTON.
Q OKAY, ] MISPRONOUNCED IT PREVIOUSLY.
A IT' S OKAY.
Q SPELL THAT EOR NIE. PLEASE?
A BETSY, B-E.T_S_Y, MANSTON/ M_A_N_S_T_O_N.
Q THANK YOU.
A
OFFICER.
AND HOW ARE YOU EMPLOYED?
I AM EMPLOYED BY COBB COUNTY PRETR]AL, AS A PF.ETR]AL
Q AND ARE YOU THE SUPERV]SING EMPLOYEE FOR MRS. MCCO1?
A I AM.
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O
CASES?
ANN ARE YOU THE SUPERVISING OFEICER IN ALL OE HE,R
A
O
AND AS PART OF YOUR SUPERVIS]NG OF HER' ARE YOU
CHARGED !,iITH KNOWING HER T/iHEREABOUTS AND HER STATUS?
THAT' S CORF,ECT .
AIID BASED ON THAT. WHERE HAS THE DEEENDANT BEEN FOR
THE 1-AST TWO OR THREE MONTTIS?
A SHE IS ORDERED TO RESIDE AT THE 275 F'ARM DRIVE. IN
MARIET'IA, GEORG]A. SHE }]AS ENTERED INTO RIDGEV]EI'i IN THE -_ T
b]AS NOTIFIED BY HER ATTORI\]EY THAT SHE _- SHE HAD ENTERED INTO
RIDGEVIEV,/, AI.JD T GOT DOCUMENTATIOI'I ON EEBRUARY EIRST CONFIRI"lING
THAT .
I AM.
OKAY.
OKAY.
AND, EOR EXAMPLE, IT SHE WERE GOING TO RETURN TO HER
DO GARDENING, OP, ANYTHING LIKE THAT, !.JAS THAT
,CI]E, D HAVE TO NOTIEY YOU ABOUT?
YES, BUT SHE'S NOT SUPPOSED TO RETURNI TO HER HOUSE.
BASED ON HER BOND REQU]F.EMENTS. WAS SHE REQUIRED TO
HOIJ S E TLT
< a,MI''tiH T r.r r]
A
O
GET A MENTA]- EVALUAT I ON ?
A
ri
EVALUAT IO}IS ?
THAT, S CORRECT .
IN GENERAL. HOVJ DO YOU ]IANDLE THOSE }IENTAL
WE ARE SUPPOSED TO RECEIVE ALL PAPERWORK ON THOSE
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EVALUATIONS. IN THIS CASE
SHE __ SHE APPEARED FOR HER
T!.iENTY- FIRST, TWO THOU SAN D
OF THE ACTUAL EVALUAT I ON /
Q HOW OFTEN DO YOU
EVALUATION I TS,EL L'?
I RECEIVED PAPERI,.JORK CONFIRMING TI1AT
EVALUATION APPO]NTI.,IENT ON DECET]BER
r]FTEEN, BUT I NEVER RECETVED A COPY
SO 1 CAN'T FOLLOW-UP ON _-
GENERALLY RECE]VE A COPY OF THE
EVALUAT ION .
A
O
DECEMBER __
A
O
A
EVERY __ EVERY CASE WE'RE SUPPOSED TO RECEIVE THE
AIJD APPROXII'IATELY HOW LONG WOULD IT TAKE FOR YOU TO
RECEIVE THAT EVALUAT I ON ?
A EVERYWHERE'S DIFFERENT. I MEAN, MOST PLACES WE GET
THEM PRETTY QUICKLY, WITHII.] A COUPLE DAYS. SOME TATiE UP TO TEN
BUS]NESS DAYS.
OKAY.
AND SO IE THE BOND WAS ORDERED IN DECEMBER __
UH_HU (AFF] RMAT IVtr )
_- AND THE MENTAL EVAI,UATIOI{ WAS ORDERED II.I
SURE.
-- WOULD YOU EXPECT TO HAVE ONE BACK BY NOW?
YES.
Q AND WHAT DOES THE ME}]TAL EVALUATION HELP YOU DO?
A IT __ IT HtrLPS US Btr ABLtr TO TF,ACK HER IN TRtr,1TMENT.
I F THEY WERE TO RECOMI,IEND ANY TREATMENT. 9.JE MAKE SURE THAT THEY
F'OLLOI/!7-UP W]TH TREATMENT YiITHII.] FOUR?EEN' DAYS OF THE
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A
ffira-r woul,p BE A VTOLATION.
AND AS IT STAI',iDS \]OT. YCU I{AV }JOT COI'IPLETED THE
PETITIOI.,] OI] -- ON YOUR PARTICULAR ORDER -_
o
A
o
SURE.
-_ I{OULD THE DEFENDANT BE IN COMPL]ANCE?
WJTH THE EVALUAT ] ON ?
A ] WOULD SAY NO, BECAUSE !'JE DON'T HAVE AT] ACTUAL
EVALUAT]ON. I HAVE BEEN TOLD THAT THERE'S -_ THERE'S MORE TO
THE EVALUATION THAT NEEDS TO BE DONE IN ORDER FOR US TO GET A
COPY.
Q SO HOW ARE YOU ABLE TO PROCEED AI':]D _- AND BE
EFEECTIVE II.{ I'IONITORING THE DEEE},IDANT WITHOUT THAT EVALUATION
BEING DOI.,]E ?
T'M NOT .
AND TS THE DEEE}JDANT REQU]RED TO STAY COMPLIANT WITH
Q LET ME ASK YOU THIS, DO YOU GO CVEF, ALL ORDERS WITH
THE DI]FENDANT WHEN THEY ARE __
ATIY ]4ED]CATIONS AS PART OF YOUR !^IORK?
A I DON' T HAVE AI'IYTHING STATII'JG THAT SHE' S -- SHE'S OLI
ANY PRES'JRIPTIONS. ] WASN'T AWARE THAT SHE'S TO BE TAKING ANY,
AND IT !,,]ASN'T ORDERED THAT SHE'S TO TAKE ANY CERTAIN TYPE OE
PRESCRIPT]ON.
YES.
BOTH YOUR ORDER, THE PRETRIAL ORDER, AIID THE COUF.T/ S
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BOND ORDERS/ AND FOLLOW_UP
UNDERSTANDS EACH AND EVERY
TO MAKE SURE THE DEFENDANT
CONDITION --
NO
WE
CORRECT .
-_ OE THE ORDERS ?
A YES.
O AND DO YOU CAUT]ON THEM ABOUT TALKING TO WITNESSES?
A YES, AND __ AND T,{E LET THEM KNOW THAT THERE'S TO BE
CONTACT, IF A NO CONTACT ORDER IS IN PLACE, AND IN THIS CASE
__ WE DID TALK ABOUT NOT HAV]NG CONTACT.
AND IE THERE WAS AN ISSUE REGARDING BOND. OR
DOCOMPLIANCE WITH A BOND, OR ANYTHING LIKE THAT/ VJHAT
DIRECT YOUR __ WHAT DO YOU DIRECT THEM TO DO THEN?
YOU
I ' M SORRY . I.^IHAT Do YOU MEAN ?
WHAT DO YOU DIRECT THE DEFENDANT TO DO ]T THEY FEEL
THAT THERE, S AN ]SSUE WITH THE BOND, THEY'RE GO]NG TO HAVE
PROBLEMS COMPLY]NG, OR THEY __ THEY EEEL THAT THEY MIGHT
V]OLATE __ VIOLATE THE CONDITIONS OF THEIR BOND. WHAT ARE THEY
TOLD TO DO?
A WE'RE TOLD __ WE TELL THEM TO TALK TO THEIR ATTORNEY
SO THAT THEIR ATTORNEY CAN DO A MOTION TO MODTEY THEIR BOND
CONDITIONS. BECAUSE THAT'S SOMETH]NG THAT'S OUT OE' MY HANDS. ]
CAN'T CHANGE WHAT THE JUDGE HAS ORDERED"
OKAY.
AND ARE YOU OPEN AND AVAILABLE TO TALK TO THE
AT ANY TIME THAT SHE HAS ANY QUESTIONS __DE EEN DANT
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A
o
ABSOLUTELY.
_- OR CONCERNS ?
MS. JACKSON: NOTH]NG EURTHER.
THE COUF.T: CROSS EXAMINATION.
MR. KILGORE: OKAY.
BY MR.
O
EVALUAT E D ?
A
0
A
SIGNED BY
CROSS EXAM]NATION
KILGORE:
YOU BECAI"]E AWARE THAT SHE WAS _- WELL. LET ME
BACK UP _-
A SLIRE.
O -- AND ASK YOU ABOUT THE EVAL.
YOU SAID YOU HAD CONFIRMAT]ON THAT SHE HAD BEEI\]
YES, I DO.
WHO _ _ I.iHO DI D YOU GET THAT EROM?
I GOT ]T EROM YOUR OEEICE, ]S THE LETTER THAT'S
KEV]N R]CHARDS.
ALL RIGHT, LET'S SEE THIS.
OKAY, SO WHAT YOU'RE SHOI,{IIJG ML], '.1'H1S 1S S'1'RAlGH'1' OU1'
OF' YOUR FTLE.
A SURE.
Q THIS IS A LETTER EROM THE FORENSICS SPECIALTY GROUP
ON lgq FRASIER STRtrET __
A Y i,5.
O __ CONFIRM]NG THAT SUSAN MCCOY APPEARED FOR HEF.
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OKAY, LET ME ASK YOU THIS. DID YOU EVER CONTACT __
BY ANY CHANCE D]D YOU EVER CONTACT KEVIN RICHARDS AND ASK HIM?
EVALUATION AS SCHEDULED.
A I DID NOT, BECAUSE THE RELEASE WAS SIGNED OVER FOR
CARLOS __
Q OKAY.
A __ THAT I WOULD GET A COPY OE THE EVALUATION.
Q ALL RIGHT.
SO YOU r/iERE NOTIFIED THAT EURTHER EVALUATION NEEDED
TO BE DONE ?
A YES.
Q OKAY.
Q UH_HUH (AEEIRMATIVtr).
A _- AND CARLOS SAID ONCE THE EURTHER EXAM]NATTON THAT
THEY NEED TO DO WAS -- WAS DONE --
AND IN PRETR]AL, YOU CAN/ T ORDER ANYBODY INTO
TREATMENT, CAN YOU?
A I MEAN, ONCE THE EVALUATION'S DONE, ANY TREATMENT
THAT'S RECOMMENDED, I CAN HELP ENFORCE THAT. BUT I DON'T ORDER
PEOPLE TO DO TREATMENT __
Q ALL RIGHT.
A __ IT IT'S NOT RECOMMENDED ON T:{E EVALUATION.
Q ALL RIGHT.
BUT YOU'RE AWARE IN THIS CASE, WE'RE KIND OF BEYOND
EVALUATION. IN FACT, YOU'RE AWARE '1'HAT SHE WAS ]N RIDGEVIE!,i
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HOSP]TAL EOR A PER]OD OE WHAT, FIVE WEEKS?
A I __ I DON'T HAVE DOCUMENTATION SHOWING !,iHEN HER
EXACT D]SCHARGE DATE WAS. THIS WAS ALL I GOT FROM RIDGEVIEb]
Q OKAY.
A -- THIS WAS ALL THEY WOULD RELEASE TO ME BECAUSE
THERE WASN'T A RELEASE EORM DONE. SO, THAT'S ALL THAT THEY
hLRE ABLE TO Gl\E ME.
Q OKAY.
DID -- DID OUR OFE']CE MAKE YOU AWARE THAT SHE WAS IN
RI DGEVIEW. THOUGH ?
ALL RIGHT.
A
0
AND __ AND, ]N EACT, YOU WERE ABLE TO CONEIRM THAT?
A YES. R]DGEVIEW ACTUALLY SENT ME TH]S CONEIRMING THAT
SHE WAS THERE/ BUT I DTD SPEAK WTTH CARLOS, AND HE HAD TOLD ME
THAT SHE WAS IN R]DGEVIEW. I DON'T HAVE THAT EXACT DATE THAT
HE HAD TOLD ME --
A
OKAY.
__ BUT I COULD GET YOU THAT DATE. IF YOU NEEDED IT
Q ALL RTGHT.
AND YOU *. 1T __ YOU HAVE NOT NOTIEIED MS. MCCOY AT
ANY TIME THAT SHE IS IN __ WELL, LET ME PUT IT THIS WAY.
YOU HAVEN'T FILED A PETITION WITH TH]S COURT TO
REVOKE, HAVE YOU?
A NO, I HAVE NOT.
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AND YOU HAVEN/T NOT]FIED HER THAT SHE'S IN __ IN
VIOLATION OE -- OF ANY -- OE ANY CONDITIONS, HAVE YOU?
A I -_ THERE ARE CERTAIN THINGS THAT HAVE CAME UP TODAY
THAT I I MEAN, THAT I !,iASN'T AWARE OE, SO I CAN ONLY EILE
EOR THINGS THAT 1 KNOW OE.
Q OKAY.
Q OKAY.
A THE THIRTY_FIVE DAY TREATMENT CENTER? YES, I __ I
GOT THAT NOTITICATION TODAY.
Q AL], RIGHT.
A ABSOLUTELY.
ALL RIGHT, AND ARE YOU AWARE THAT, IN EACT, SHE HAS
PLACEMENT ]N A LONG TERM CARE FACILITY?
AND HOW DID THAT COME TO YOU?
A CARLOS HANDED ]T TO ME TODAY.
Q ALL RIGHT.
DO YOU HAVE THAT WITH YOU?
A I DO.
Q ALL RIGHT, COULD ] SEE THAT?
A SURE.
Q AND IN DO]NG YOUR WORK AS A PRETRIAL OTT]CER, ]E
SOMEONE ]S RECOMMENDED TO RECEIVE MENTAL HEALTH TREATMENT, YOU
__ YOUR OFFICE DOSEN'T __ ] MEAN, YOU CONCUR WITH THAT, DON'T
YOU? I MEAN, YOU AGF,EE THAT IE IT/ S __ IF IT' S tr.ECOMMENDED, IF
IT' S NEEDED, THAT __
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O __ THAT NEEDS TO BE DONE?
A R]GHT.
Q ALL RIGHT.
AND SO YOU'VE RECEIVED TH]S TODAY INDICATING THAT MS.
MCCOY ]S APPROVED EOR A RES]DENTIAL TREATMENT CENTER BEGINNING
AS EARLY AS YESTERDAY ?
AND DlD YOU ALSO RECEIVE FLIGHT INEORMAT]ON EOR
TOMORROW, FRIDAY THE EIGHTEENTH, TO FLY TO AR]ZONA TO BE A PART
OE THIS PROGRAM?
A YES.
Q ALL RIGHT.
A YES.
Q ALL RIGHT.
DO YOU HAVE ANY V\r'AY TO EOLLOW UP ON THIS AT SABINO
RECOVERY IN TUCSON, AR] ZONA?
A AS LONG AS A RELEASE EORM IS SIGNED OVER __
Q OKAY.
A __ WITH MY NAME ON IT. THEN YEAH, ] CAN EOLLOW_UP ON
IT __
Q OKAY.
A __ AND TRACK IT.
Q AND PRETR]AL DOESN'T HAVE ANY OBJECTION TO MS. MCCOY
GETTING THE HELP THAT SHE NEEDS, DO YOU?
A NO OBJECTION.
Q OKAY.
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MR. KILGORE
THE COURT:
MS. JACKSON
THE COURT:
THE W]TNESS
MS. JACKSON
THE COURT:
MS. JACKSON
THANK YOU.
ANY REDI RECT ?
NO, YOUR HONOR.
YOU CAN STEP DOWN, THANK YOU.
THANK YOU.
THE STATE CALLS _-
WHO' S NEXT, PLEASE.
-_ DOCTOR MATTHEW NORMAN .
MATTHEW NORMAN,
SWORN, WAS EXAM]NED AND TESTIFIED
DIRECT EXAMINAT I ON
HAVING BEEN FIRST DULY
EOLLOWS :
BY MS. JACKSON:
AS
STATE YOUR NAME FOR THE RECORD.
MATTHEW NORMAN, M_A-T-T_H-E_W, N-O-R-M-A-N.
HOW ARE YOU EMPLOYED?
I HAVE A PRIVATE PRACTICE OE GENERAL AND EORENSIC
PSYCH]ATRY, IN ATLANTA, GEORGIA.
I COMPLETED MY UNDERGRADUATE DEGREE MAJORING IN
PHYCOLOGY AT THE UNIVERSITY OF VIRGINIA __
AND HOW LONG HAVE YOU BEEN EMPLOYED IN THAT CAPACITY?
SINCE TWO THOUSAND AND TWO.
AND T.JHAT ]S YOUR EDUCATION?
MR" KILGORE: JUDGE. I'M GOING TO STIPULATE TO DR.
NORMAN/S CREDENTIALS. I'VE WORKED WITH HIM IN THE PAST,
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HE'S A PERSONAL ER]END OE M]NE, AND I -_ AND I __ I AGREE
HE,S AN EXPERT IN WHAT HE DOES.
MS. JACKSON: THANK YOU.
THE COURT: WE,LL ACCEPT HIM AS SUCH.
O (BY MS. JACKSON) AND HAVE YOU BEEN CONSULTING WITH
THE STATE ON THE CASE, THE STATE VERSUS SUSAN MCCOY?
A ] IiAVE .
Q AND ARE YOU EAMILIAR I,dITH THE FACTS ]N THE CASE?
A SOME OE THEM, YES.
Q AND HOW IS IT YOU'RE EAMILIAR WITH THE EACTS IN THE
CASE ?
A YOU CONTACTED ME, AND WE,VE HAD A COUPLE OF' __ A
COUPLE OE TEIEPHONE CONVERSATIONS ABOUT SOME OE THE FACTS ABOUT
THE CASE, AS WELL AS YOU PROVIDED ME WITH SOME DOCUMENTS THAT
],VE HAD AN OPPORTUNITY TO REVIEW.
Q SO WHAT DOCUMENTS HAVE YOU REVIEWED?
A I,VE REV]EII]ED A ONE PAGE DOCUMENT FROM A DOCTOR KEV]N
RICHARDS. THAT WAS DATED DECEMBER TWENTY_SECOND OF TWENTY
FIFTEEN. IT'S JUST A ONE PAGE DOCUMENT.
]N ADDITION ] HAD A COPY OE AN EMAIL EROM PAUL
CAMARILLO. IF I PRONOUNCED THAT CORRECTLY, RELATED TO A --
BAS]CALLY A VlSlT THAT HE HAD EROM MS. MCCOY ON FEBRUARY
TWENTY_NINTH OF TWO THOUSAND AND SIXTEEN.
] WAS ALSO PROV]DED A COPY OE A COBB COUNTY POLICE
DEPARTMENT INVESTIGATIVE SUMMERY, SUMMARIZING MOSTLY
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ALLEGATIONS RELATED TO MS. MCCOY, S CASE, AND
OLEN S .
ATTORNEY GENERAL
IN ADDIT]ON TO THAT, TODAY I GOT SOME RECORDS RELATED
TO __ EROM RIDGEV]EW HOSPITAL, THAT S]MPLY WAS KIND OF A ONE
PAGE VER]EICATION TIiAT SHE HAD ATTENDED THE PARTIAL
HOSPITALIZATION PROGRAM.
O
PARI S ?
A
THAT IS
O
WORK __
A
O
A
O
A
o
S TALK] NG ?
I DlD REVIEW SOME DOCUMENTS REGARD]NG MICHAEL PARTS/
CORRECT.
OKAY.
AND YOU A],SO REVIEWED DOCUMENTS REGARDING MICHAEL
AND DO YOU EVALUATE DEEENDANTS AS PART OE YOUR
YES.
__ FORENSIC SIDE __ AND ON THE EORENSIC SIDE?
AND YOU WORK FOR THE STATE AND
YES.
OKAY.
AND ARE YOU EAM]LIAR THAT THE
FOR THE DEFEN SF]?
DEEENDANT'S CHARGE WITH
Q AND
DANGEROUSNtrSS
YES.
HAVtr YOU RtrAD ANY STUDItrS RtrGARD]NG THE POSSIBLE
OF DEEENDANTS CHARGED WITH STALKING?
SO PART __ PART OF MY PRACTTCE IS DOINGA YES.
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EVALUAT]ONS FOR WHAT THEY CALL V]OLENCE RISK ASSESSMENT. THOSE
INCLUDE SOME ]ND]VIDUALS W]TH STALKING CHARGES, SOME
TNDIVIDUALS THAT MAY NOT HAVE STALKING CHARGES. BUT IT'S AN
EMPLOYER/ EMPLOYEE S]TUATION WHERE THERE MAY BE SOMEONE WHO MADE
A STATEMENT, AND IT'S ESSENTIALLY CALLED A E]TNESS EOR DUTY
EVALUATION, BUT PART OF MY PRACT]CE IS DOING V]OLENCE RISK
ASSESSMENTS.
Q AND BASED ON YOUR STUDIES WITH VIOLENCE RISK
ASSESSMENTS, YOU REVIEWED THE MATERIALS, WHAT WOULD YOU SAY
ABOUT A PARTICULAR S]TUAT]ON OE' A PERSON, A E'EMALE, WHO STALKS
PUBL]C OEE]CIALS, PEOPLE WHO ARE NOT PERSONALLY RELATED TO
THEM?
A SO THEIR __ WITHIN THE LITERATURE OF STALKERS AND
STALKING BEHAVIOR. ONE, SOMEONE THAT'S A TEMALE STALKER
STALKING MALES, ALLEGEDLY IS NOT AS COMMON AS __
MR. K]LGOF.E: JUDGE/ I, LL TELL YOU WHAT. YOU KNOI,{
WHAT/ I THINK ]'M GOING TO OBJECT TO JUST A __ JUST A
GENERAL CONVERSATION ABOUT IT. IE HE'S REVIEWED SPEC]F'IC
MATERIALS AND HAS SOME OPINION. I DON'T KNOW THAT 1T'S
PARTICULARLY RELEVANT, BUT TT I^]OULD CERTAINLY BE MORE
RELEVANT THAN JUST SOME __ SOME GENERAL CONVERSAT]ON ABOUT
PEOPLE CHARGED W]TH STALKING IN GENERAL. HER CASE IS HER
CASE. 1 DON/T KNOW WHAT IT IS HE'S TALKING ABOUT. Wtr
COULD BE TALKINC ABOUT PEOPLE WHO EVENTUALLY USE VIOLENCE.
OR __ I DON'T KNO!{, BUT I DON'T TH]NK IT'S RELEVANT.
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THE COURT: WHAT, S YOUR RESPONSE TO THAT?
MS. JACKSON: OKAY. THE PARAGRAPH IS TALKING ABOUT
THE DEEENDANT,S DANGEROUS, G]VEN HER BEHAVIOR, THE FACT
THAT SHE'S NOT ON MEDICATION, AND HER GENERAL HARASSING
AND INTIMIDATING BEHAV]OR.
THE COURT: WELL, THE OUESTION GOES
MS. JACKSON: DOCTOR NORMAN TS --
THE COURT: THE QUESTION GOES TO THE
LITERATURE THAT HE REV]EWED TO THIS CASE.
OB JECT I ON .
MS. JACKSON: RIGHT. DOCTOR
THE QUESTION MORE ARTEULLY __
THE COURT: OKAY.
MS. JACKSON: -- BUT DOCTOR
TO TALK ABOUT SPEC]E]C LITERATURE
FEMALE STALKERS WHO STALK PEOPLE
PERSONALLY RELATED.
NORMAN IS -- I WTLL ASK
RELEVANCY OE THE
THAT , S THE
NORMAN IS ACTUALLY GOING
THAT HE' S REVIEWED ABOUT
WHEN THEY'RE NOT
THE COURT: I,LL OVERRULE THE OBJECTION, ASSUMING
THAT IT'S GO]NG TO GO TO SOME MORE SPECIE']CS.
Q (BY MS. JACKSON) DOCTOR, GO AHEAD.
A WELL, THERE ARE A NUMBER OF STUDIES, AND IN MY
EXPERIENCE AND TRAINING, THERE ARE A NUMBER OE STUDIES, MOST OF
WH]CH ARtr IN THtr E'ORtrNSIC/PSYCHIATRIC LITtrRATURE, SO EOR,ENSIC
PSYCHIATRISTS, AND MORE SPECIFICALLY/ THEY THEN BREAK STALKING
DOWN INTO DIEEERENT SUBCATEGORIES, EIGHT ROUGH SUBCATEGORIES.
72
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THE ONE THAT THIS PARTICULAR CASE DEALS WITH IS !{HAT IS
CATEGORIZED AS A RESENTEUL STALKER, WHERE THEY ARE -_ THEY FEEL
WRONGED IN SOME WAY, OR MISTREATED IN SOME WAY, AND THEN START
TO APPLY THAT BEHAVTOR INAPPROPRIATELY TOWARDS THE TARGETS OR
THE VICT]MS OF THEIR STALK]NG BEHAVIOR.
Q BASED ON THE STUDIES, VJHAT ]S THE POTENTTAL
DANGEROUSNESS OE' THESE TYPES OF PERSONS?
A SO THE _-
MR. KILGORE: oH COME ON. JUDGE, OBVIoUSLY I'M GOING
TO OBJECT TO THAT. LET'S HAVE TH]S W]TNESS SAY THE WORST
POSSIBLE CASE SCENARIO THAT DOESN, T HAVE ANYTHING TO DO
WITH THIS PART]CULAR CASE.
]F HE/ S GOT SOMETHING RELEVANT TO PARAGRAPH FOUR/
I,,,]HICH SAYS, THE DEEENDANT'S A DANGER TO THE COMMUN]TY,
SHE'S DEMONSTRATED ]RRATIONAL BEHAVIOR AETER RECENT
HOSPITALTZATTON. THAT'S THE ONLY THING THAT'S BEEN"
CHARGED HERE AS A VIOLATION. SO, I THINK THE EXAMINATION
HAS GOT TO BE FOCUSED AROUND WHAT THE ALLEGATION IS.
OTHERWISE IT/S JUST NOT RELEVANT.
MS. JACKSON: I CAN -- !{ELL -- WELL, YOU KNOW,
REPHRASE THE QUESTION.
Q (BY MS. JACKSON) BAStrD ON YOUR STUDY OF THE
LITERATURE ON AND YOUR STUDY OF THE POLICE REPORTS/ WERE YOU
ABLE TO DETERMINE !^iHAT TYPE OF STALKING BEHAVIOR THE DEFENDANT
WAS ENGAGING IN?
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YES.
OKAY.
!{HAT TYPE OE BEHAVIOR IS THAT?
]T, THE RESENTEUL STALKING BEHAVIOR.
AND BASED ON THAT TYPE OE STALKING BEHAV]OR' WOULD
THE DEEENDANT, S BEHAVIOR BE CONSISTENT W]TH _- I''ITH THE __
WOULD THE DEEENDANT,S BEHAV]OR BE CONSISTENT I,d]TH THAT OE A
REVENGEFUL STALKER?
A YES.
AND BASED ON THAT, V,IHAT
A
O
APPROPRIATE RECOMMENDATION TO ASK
THAT SOCIETY WOULD NOT BE HARMED
BEHAVIOR.
WOULD BE __ WHAT WOULD BE AN
THE COURT TO DO TO ENSURE
BY THIS PARTICULAR DEFENDANT'
MR. KILGORE: JUDGE, OBVIOUSLY THAT, S OBJECT]ONABLE.
SHE'S EITHER VIOLATED THE CONDITIONS OR SHE HASN'T. IT/S
__ IT'S NOT UP TOR HIM TC DETERMINE !^IHAT THE COURT NEEDS
TO -_ WHERE THE COURT NEEDS TO GO EROM HERE.
IF __ IF THE COURT ULTIMATELY MAKES A F]NDING THAT
SOMEHOW WHAT WE'VE HEARD IS IN ANY WAY. SHAPE, OR EORM, A
VIOLATION OF HER BOND CONDITION, AT THAT POINT IN TIME ]F
THE COURT WANTS TO HEAR EROM A !,,]ITNESS, HEY, !,iHAT DO YOU
THINK WE OUGHT TO DO ABOUT THAT, SHOULD __ SHOULD WE LET
HEtr. GOT TO ARIZONA OR NOT? THAT WOULD BE TIIE APPROPR]ATE
TIME TO ASK THESE OUESTIONS.
SO, I JUST __ AT THIS POINT IN T]ME IT, S NOT -- TT, S
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NOT A RELEVANT INQUIRY. IT'S UP TO YOU TO DETERMTNE
FACTUALLY SHE'S EITHER VIOLATED OR SHE HASN'T.
MS. JACKSON: OKAY.
THE COURT: ] THINK IT CALLS EOR A LEGAL CONCLUSION.
MS. JACKSON: I'LL -- I/LL ASK -- I/LL ASK IT A
DITTERENT WAY.
Q (BY MS. JACKSON) BASED ON THE POLICE REPORTS THAT
YOU READ, IF YOU UNDERSTOOD THAT SOMEONE WHO ENGAGED IN THE
TYPE OE BEHAVIOR THAT HAS BEEN REPRESENTED IN THE POLICE
REPORTS AS -- IN REEERENCE TO THE DEFENDANT, WOULD YOU EXPECT
THAT DEEENDANT TO HAVE TO BE MEDICATED?
A T WOULD. TN MY EXPERIENCE TF SOMEONE HAS BEEN
ADM]TTED TO A PSYCHIATR]C HOSPITAL AND HAS A PSYCH]ATR]C
DIAGNOSIS WITH THE ALLEGED STALKING BEHAVIOR, NONE COMPLIANCE
W]TH MEDICAT]ONS SIGNIFICANTLY lNCREASES THE R]SK OE' VIOLENT
BEHAVIOR.
THE COURT: YEAH, I,M GOING TO SUSTAIN THAT
OBJECTION.
Q OKAY.
AND SO HYPOTHETICALLY, A PERSON SAID __ BEEN
HOSPITALIZED, I'M TH]NK]NG CLEARLY NOW, ]'M __ SO I DON'T HAVE
TO TAKE ANY MEDICATION, WOULD THAT BE AN AREA OE CONCERN?
A AS A FORENSIC PSYCHIATRIST/ THAT WOULD BE AN AF,EA OF
CONCERN, YES, IT !,iOULD.
Q AND WHAT WOULD THE CONCERN BE?
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A THAT WHETHER THAT WAS A -_ WHETHER THAT WAS AT THE
DIRECT]ON OE A PRESCRIBING PHYSICIAN TO DISCONTINUE THOSE
MEDICATIONS, OR THAT WAS AT THE DISCRETION OE THE INDIVIDUAL
WHO' S ACCUSED OF THE ALLEGED STALKING BEHAVIOR AND __ AND MAY
NOT BE THINKING CLEARLY.
Q AND !^IHAT WOULD -- HOW WOULD -- HOW WOULD THE NOT
TH]NKING CLEARLY. HOh] WOULD THAT BEHAVIOR BE MANIFESTED IN
SOMEONE I,iITH THIS PARTICULAR __
A USUALLY THE RESENTEUL STALKERS ARE __ THEY HAVE SOME
DELUSION, THEY HAVE SOME PSYCHOSIS THAT IS PRESENT, AND __ AND
THEY BELIEVE THAT THEY ARE THINKING CLEARLY, AND IF YOU TALK TO
A LOT OE OTHER PEOPLE, OR IE YOU TALK TO THE]R CLINICIANS,
THEIF. CL]N]CIANS I,iOULD D]SAGREE. AND WOULD RECOMMEND THAT THEY
MAINTA]N THEIR MED]CATION AND MAINTAIN THEIR MENTAL HEALTH
TREATMENT.
Q AND IF THEY ARE NOT ON TREATMENT, WOULD YOU __ UNDER
TREATMENT, OR MAINTAIN]NG THEIR TREATMENT, WOULD YOU EXPECT
THEM TO BEG]N THAT STALK]NG BEHAVIOR AGAIN?
A I WOULD EXPECT THEM TO POTENTIALLY REENGAGE IN THAT
BEHAVIOR.
A THAT'S THE R]SK, ]S THE RISK EROM ALL THE STUDIES/
Q WHATEVER THAT BEHAVIOR WAS?
A WHATEVER THAT BEHAVIOR WAS BEFORE.
Q AND WHAT ABOUT THE POSSIBILITY OF ESCALATION OF THAT
BEHAVIOR?
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AND IN MY EXPER]ENCE, IS THAT -- THAT IT'S THE NON_TREATMENT OF
THE MENTAL ILLNESS THAT CAN ALLOW THE BEHAVIOR TO CONTINUE AND
ESCALATE.
Q OKAY. AND WHEN YOU SAY ESCALATE, WHAT DO YOU MEAN BY
THAT ?
A WELL, IT DEPENDS ON ViHAT BASELINE IT STARTED AT, BUT
THE _- THE I/,IOF.ST RISK IS A RISK EOR VIOLENCE.
Q AND IE YOU START OUT WITH EMAILS, MULTIPLE EMAILS,
NICE EMAILS, THEN STARTED GOING TO MORE EMAILS/ AND THEN
STARTED GO]NG TO ]MPLIED THREATS, WHAT WOULD YOU EXPECT TTiE
NEXT STEPS TO BE?
MR. KILGORE: I'M GOING TO OBJECT TO THE EORM OE THE
QUESTION. INSTEAD OE SOME GRAND, BROAD GENERALIZATION,
LET'S SHOW EXACT]-Y WHAT TT IS SHE'S SUGGESTING. LET'S
SHOW HIM EXACTLY WHAT __ WHAT ARE WE TALKING ABOUT? LET'S
SEE WHAT IT IS.
THE COURT: 1 TH]NK, AND YOU ALL CAN EIGURE OUT HOW
TO POSE THIS. OR I CAN JUST ASK IT, BUT YOU KNOW. ONF __
ONE QUESTION I NEED ANSWERED IS, HOW DO THESE TEXT
MESSAGES RELATE TO THE CONCEPT OT BEING A RESENT!'UL
STALKER? THAT'S REAT,I,Y SOMETHING I NEED ANSWERED.
SO, ] THINK YOUR QUESTION'S A LITTLE BIT OVER __
OVERLY BROAD. 1'M GOTNG TO SUSTAIN THE OBJECTION/ BUT I
THINK THAT LOOKING AT WHAT I^iE HAVE FROM THIS BOND
CONDITION BEEORE THAT'S OCCURRED IS WHAT'S *- A QUESTION I11
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(BY MS. JACKSON) I'M GOING TO SHOW YOU STATE'S
EXHIBITS ONE, TWO AND THREE.
A
Q (BY MS. JACKSON )
OPPORTUNITY TO V]EW THE TEXT
A I DON'T KNOW THAT
PEC!-'JT TE\T MLSSAGES.
THE OB.TECT OF THEIR PREV]OUS
A THAT OE'TEN T]MES _-
__ THAT THE GOAL IS TO CAUSE
NF]ED TO HAVE ANSWERED, WHAT DO
AtsOUT THIS DEEENDANT AI.i D THiS
CONDITION.
THE CURREI]T EACTS TELL US
RESEN?FUL STAIKI}.IG
HAVE YOU __ HAVE YOU HAD THE
MESSAGES THAT WERE SENT ?
I'VE HAD AN OPPOF.TUNITY TO SEE THE
OETEN TIMES A RESEI.ITEUL STALKER
PATN TO SOMtrONtr ELSE IN SOMtr WAY
MS. JACKSON: MAY I APPROACH THE WITNESS?
THE COURT: YES.
YES.
HAVE YOU HAD THE OPPORTUI.]ITY TO REV]EW THEI"{?
VtrC T IIA\/tr
AND WOULD MESSAGES OE THAT TYPE BE CO}ISISTENT IiiITH
THE TYPE OF BEHAVIOR EXEMPLIElED BY THE RESENTFUL STALKER?
SO IE SOMEONE HAS BEEN INSTRUCTED TO NOT MAKE CONTACT
WITH THAT INDIVIDUAL. AI.JD HAS NOT BEEN __ HAS BEEN COMPLY]NG
WITH THAT, EROM A PSYCH]ATRIC STANDPOINT, IE THEY THEN REENGAGE
IN THAT BEHAVIOR, IT IS AN ESCALAT]ON OE THE BEHAVIOR AND IS A
-- ]S A -- OE CL]NICAL CONCERN R]SK FACTOR.
Q NOW, I,I]HAT IF THEY ARE ENGAG]NG WITH PEOPLE CLOSE TO
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THAT THEY EELT L]KE THEY HAD PUT ON THEMSELVES. THAT'S WHAT
THF' B.ESENTEUL STALKER TRYS TO DO. AND IF THEY' RE TOLD NOT IO
CONTACT THE PERSON AT THE CORE, AT THE CENTER, THEY MAY WALK
AROUND THE PERIPHERY AND SEE HOW THEY CAN GET TO THOSE PEOPLE,
GET AS CLOSE AS THEY CAN TO THAT PERSOIJ AT THE COP,E, PEOPLE AT
THE CORE OE THE ISSUE, AND START CONTACTING THEM.
Q AND !.JOULD THAT IIICLUDE A _- A CLOSE I'RIEND OF THE
OBJECT ?
A YES, CLOSE ER]END OR EAMILY MEMBER.
Q I,'OULD IT ]NCLUDE MAYBE REFI]RENCE TO SOMETH]NG,
SOMETHINIG THAT THE OBJECT OE THE STALKING WOULD ONLY __ WOULD
UNDERSTAND, WOULD BE A REFERENCE TO THEM?
A YES, AN]D THE -- AT THE END OE THE DAY, THE CONCERI.]S
OF' THE EORENSIC PSYCHIATRIST IS THAT THE THOUGHTS ARE STILL ]N
THE II\]DIVIDUAL, S HEAD WHO, S ACCUSED OF. THE ALLEGED STALKING,
THAT THEY HAVEN'T LET IT GO. THAT'S THE WHOLE POINT OF
TREATMENT, IS SO THAT TH]S CAN BE LET GO ]N THEIR M]ND SO ]T'S
NOT THERE ANYI'1ORE, AND THEN THE BEHAVIOR CAI\] STOP.
Q AND SO IF A PERSON WAS TOLD NOT TO CONTACT A
PARTICULAR PERSON/ AND THEY CONTACTED A CLOSE FRIEND OE THEIRS,
REEEREIICING AN OBLIGATION, OR SOMETHING ABOUT 'IHAT RELATIOI.ISHIP
WITH THE THIRD PARTY, WOULD THAT BE CONSTSTENT WITH THE
BEI.IATJIOP, OF A RESENTFUL STALKER?
A IT WOULD, BECAUSE IT SAYS, FROM A CL]NITION'S
STANDPOINT, IT SAYS THAT THE PERSON ]S ST]LL THINKING ABOUT THE
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TARGET. THE ORIGINAL TARGET VICTIM OE THE STALK]NG, AND THEY'VE
ST]LL GOT IT IN THEIR HEAD, AND THAT'S THE CONCERNING BEHAVIOR,
IS THAT IT'S ST]LL ]N THEIR HEAD.
Q AND ON __ ONE OTHER QUEST]ON REGARD]NG THE REVENGEE'UL
STALKER TYPES. HOW DO THEY ]NTERACT? WHY IS IT THAT EVEN WHEN
THEY HAVE A SUPPORT SYSTEM, THEY HAVE EAM]LY MEMBERS OR ERIENDS
WHO TRY TO HELP THEM TO STOP THE BEHAVIOR, ARE UNABLE TO STOP
ON THEIR OWN?
THAT' S WHERE _-
MR. KILGORE: JUDGE, I,M GOING TO OBJECT AGAIN. I
MEAN, WE -- WE,RE SO EAR AEIELD TALKING ABOUT ALL THESE
GENERAL CONCEPTS. FOR GOODNESS SAKES, LET'S TALK ABOUT
TH]S CASE. IT,S JUST NOT __ IT'S JUST NOT RELEVANT.
HE'S NEVER EVALUATED THE WOMAN, JUDGE. I MEAN/ IE
HE'S GOT SOMETHING VERY SPECIEIC TO TH]S CASE, ] TH]NK THE
COURT COULD HEAR ABOUT IT, BUT I MEAN, WE'RE TALKING ABOUT
*- THIS IS LIKE SOME SORT OF CLASS OR SOMETHING ON _- ON A
TOPIC THAT'S WAY TOO GENERAL. ]'M GO]NG TO OBJECT TO THE
EORM OE THE QUEST]ON. ITIS JUST NOT RELEVANT.
MS. JACKSON: IT/S PEREECTLY ACCEPTABLE FOR AN EXPERT
TO REVIEW MATERIALS IN THE CASE AND TO BE ABLE TO, BASED
ON THEIR EXPERTiSE AND EXPERIENCE, TO BE ABLE TO ANSWER
QUESTIONS ABOUT THAT. OR MAKE AN OPINION ABOUT THAT
SPECIFIC -- SPECIEIC CASE, WITHOUT HAV]NG ACTUALLY
EVALUATED THE SUB.]ECT __ THE SUB.]ECT __
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THE COURT: GO AHEAD. T,LL ALLOW IT.
MS. JACKSON: __ BASED ON EACTS WHICH THE EXPERT HAS
BEEN SUPPLIED I"i]TH.
THE COURT: I' M GOING TO ALLO!^J IT .
Q (BY MS. JACKSON) OKAY, ],LL REPEAT --
A YES. SORRY.
Q I,LL REPEAT MY QUESTION.
A THANK YOU.
Q OKAY.
HOW -_ HO!{ IS IT THAT SOMEONE WHO IS A REVENGEEUL
STALKER TYPE IS UNABLE TO STOP -- TO STOP THEIR BEHAVIOR, EVEN
IF THEY HAVE A SUPPORT SYSTEM, OR ERIENDS, OR FAMILY MEMBERS,
OR OTHERS, TO TRY TO HELP THEM STOP THE BEHAVIOR?
A ]N THE MAJORITY OE THOSE CASES, IT'S BECAUSE THERE'S
A MENTAL ILLNESS THAT'S -- THAT' S UNTREATED, OR UNDER TREATED.
O AND IF YOU WERE PRESENTED WITH FACTS THAT EVEN WITH A
SUPPORT SYSTEM, EVEN WITH SPECITIC RULES THAT HAD BEEN PUT IN
PLACE, WHERE YOU HAVE THAT PERSON THAT CONTINUES TO TRY TO FIND
!,JAYS TO CONTACT OR VIOLATE THOSE RULES. i/iHAT DOES THAT
INDICATE ?
A WELL THAT, ]N ADDITION TO SEEING THAT THERE WAS THIS
VISTT TO RlDGEVIEW HOSPITAL, IN ADDITION TO A FOLLOW_UP
CoNVERSATION WITH SOMEONE IN THE COBB DA'S OtrtrICtr SAYING/ HEy,
I'M NOT TAKING MY MED]CATIONS. AND ] LEET. GIVES THE INDICATION
TO ME, AS A CLINICIAN, TIIAT TI1AT TIIE MENTAL ILLNtrSS IS81
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ONE, T}IERE IS A MENTAL ILLI']ESS; AND TWO, IT 1S I]IGHLY LIKELY
]T, S UI']DER TREATED AT THE CUP.RENT STAGE. AN"D THAT THE PERSON, S
STILL THINKING ABOUT THE TARGETS THAT THEY HAD ORIGINALLY HAD
CONTACTED AND BEEN TOLD NOT TO CONTACT.
b]OULD YOU SAY THAT THOSE TARGETS I,{OULD BE ]N DANGER?
MR. KILGORE: I'M GOING TO OBJECT. THAT'S -- THAT'S
WAY TOO GEI'JERAL, THAT' S WAY TOO BROAD .
Q (BY N1S. JACKSON) BASED ON WHAT YOU .TUST REVIEI'JED,
AND WHAT YOU'RE UNDERSTANDING IS OF THIS CASE AND OF TH]S
?CPIC, h]CULD YOU SAY TIIAT TItOSF TARGETS WOULD BE IN DA},]GER?
MR. KILGORE: REIJEW MY OBJECTION.
THE COURT: I'M GOING TO OVERF.ULE.
GO AHEAD.
THE T,iTTNESS: ALL RIGHT. ASSESSING DANGEROUSNESS IS
A DIFEICULT TH]NG, OE COURSE, A}']D PREDICTING
DAI,]GEROUSNESS. I THINK THE KEY ISSUE IS __ IT CERTAI},ILY
SAYS THAT THEY ARE A GREATER RTSK THAN WITHOUT THAT
TREATMENT.
MS. JACKSON: OKAY.
NOTHl}JG FURTHER.
THE COUR?: l',lR. KILGORE, YCUF. wITtJESS.
MR. KILGORE: JUDGE, WE __ WE,RE GOING TO BE HERE EOR
WHILE. SO, IS THEP.E ANY __
THE COURT: idE CAII COME BACK TOMORROb].
MR. KILGORE: -- IS THERE ANY !^JAY THAT WE COULD HAVE
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A RESTROOM BREAK? MS. MCCOY NEEDS TO GO TO THE BATHROOM.
THE COURT: SURE. OKAY.
MR. KILGORE: THANK YOU.
THE COURT: TAKE TEN MINUTES.
WHEN YOU SAY A WHILE, II]HAT IS A WHILE? WE,RE
STOPPING AT EIVE NO MATTER !,JHAT.
MR. KILGORE: OKAY.
THE COURT: WE,LL HAVE TO COME BACK TOMORROW
AETERNOON.
MR. KILGORE: OKAY. THANK YOU.
TEN MINUTES ?
THE COURT: TEN M]NUTES.
(SHORT RECESS TAKEN )
THE COURT: MR. KILGORE, YOUR WITNESS.
MR. KILGORE: THANK YOU, JUDGE.
CROSS EXAMTNATION
BY MR. KILGORE:
Q OKAY, DOCTOR NORMAN, LET __ LET ME -- LET ME START
OUT, I WANT TO MAKE IT REAL CLEAR THAT WE KNOW EXACTLY WHAT IT
IS THAT YOU'VE LOOKED AT IN -- IN EORMING WHATEVER OPINIONS 1T
IS THAT YOU HAVE FORMED.
SO, ]E YOU CAN GO BACK OVER THOSE IN JUST A L]TTLE __
A LITTLE MORE DETAIL IOR ME, PLEASE?
A SURE. AN EIGHT PAGE WiTH A FAX TRANSMISSION FROM
R]DGEVIEW INSTITUTE,
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Q EIGHT PAGES FROM R]DGEVIEW?
A YES.
Q OKAY.
A DATED TWO ONE OF SIXTEEN. AND THERE'S ROUGHLY THIRTY
ADDIT]ONAL PAGES. IT !^iAS SEI.IT AS A PDE, THAT II]CLUDES A LETTER
TO CARI,OS RODRTGUEZ/ DATED DECEMBER TWENTY_SECOND, TWENTY
EIETEE}i, EROM DOCTOR KEV]}J RICHARDS.
Q OKAY.
A EORWARDED EMAIL T'ROM PAUL CAMARILLO, DATED EEBRUARY
TWE}']TY_NINE, T!{EI'JTY S]XTEEN, TO SHARLA JACKSON.
Q I,^JAS IT __ THAT VJAS, I'M SORRY, ONE EMAIL?
A ONE EMAIL __
Q OKAY.
A __ YES.
COBB COUNTY SHERIEE'S OF'FICE ARREST AND BOOK]NG
REPORT ON MS. I"ICCOY. CRIMINAL WARRANT NUMBER 15_W_9551.
A COBB COUNTY MAGISTRATE COURT DISCLOSURE STATEMENT
IN STATE OT GEORGIA V. SUSAN JANETTE I"ICCOY.
Q D]D YOU SAY A WHAT. A DISCLOSURE STATEMENT?
A IT SAYS, COBB COUNTY MAG]STRATE COURII DISCLOSU]IE
STATEMENT.
Q OKAY.
A A ONE PAGE MEMORANDUM TO VTC REYNOLDS FROM __ IT'S A}I
ILLEGIBLE S]GNATURE. IT SAYS PER THE REQUEST OE CH]EF ADA DON
GEAR.Y, REEERENCE TO WARRANT 15-W-9551.
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A
COBB COUNTY POLICE
NUMBEF. 15-a991 5'7 .
INCIDENT/INVESTIGATIVE REPORT CASE
-LATL.
Q ALL RIGHT, SO THAT'S EVERYTHING YOU F.EVIEWED?
A THE TEXT MESSAGES ] JUST R.EVIE!^JED.
Q OKAY.
OKAY, LET,S START I"JITH THE EIGHT PAGES EROM
RIDGEVIEW. LET ME __ LET I"{E A LOOK AT THAT A},] D SEE IE I
UNDERSTAI.ID WHAT ]T IS YOU'RE TALKING ABOUT.
THIS IS WHAT __ AND YOU GOT IT D]RECTLY FROM
R]DGEVIEI,!?
A NO. I WAS HAI']DED IT TODAY BY -- I E I CAN READ THE
NAME CN THE ERONT.
Q BETSEY MAN STON ?
A YES.
O OKAY.
HOI,4 MANY PAGES I S THAT ?
TWE\]TY-ONE.
OKAY .
!{HAT ELSE?
THAT IS THE EXTENT OE THE F]LE THAT ] WAS SENT BY THE
ALL RIGHT, AllD TT'S NOT A -- TT'S NOT A DISCHARGE
OR ANYTHlNG OF THAT NATURE?
]T IS NOT. IT LOOKS LIKE IT/S A __ ESSENTIALLY AS IT
TO B,IDGEVIEW/ A O}.]E PAGE VERIFICATION OF
SUMMARY /
A
F.ELATE S
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a
A
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YOU HAD
YOU HAD
A
PAGES.
A
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A
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A
A
OKAY.
-_ HER BEING THERE ON EEBRUARY EIRST.
ALL RIGHT, AND LE,T ME SEE THE THIRTY PAGE
THIRTY PAGE POL]CE REPORT? COBB COUNTY _.
COBB COUNTY POL]CE RE PORT ?
YEAH, ] SAID WAS __ I THINK I SAID IT WAS
-- YOU SAI D
YOU SAI D
TWENTY -ON E
.IWENTY_ONE, OKAY, LET __
SO THAT' S SOMETH]NG THAT
LET ME SEE THAT.
YOU READ AND RELIED ON?
A
O OKAY ,
ALL RIGHT, AND -_ I MEAN. LOOK. YOU -- IT'S NOT
EOR YOU TO GET POLICE -_ POLICE REPORTS IN AI.]Y CASE.U NCOMMON
IS IT?
A
O
SIDE, AND
NO.
OKAY, BECAUSE THAT
THAT ' S THE POLIC]]
THAT IS CORRECT.
OR A IJI TNES S SIDE
THAT IS CCRP.ECT.
__ RI GHT ?
K]ND OF TELLS THE STORY FROM ONE
S]DE?
BUT YOU -.YOU'VE TESTIFIED
DEFENSEI SO CEF.TA]NLY YOU WOULD AGREE
ARETI'T ALUJAYS EXACTLY ACCURATE. THEY
REPORT BECAUSE THEY'RE EROM ONE SIDE,
FOR BOTH THE STATE AND THE
THAT THOSE POLICE RE PORTS
ARE -_ THEY'Rtr A BIASED
NOT THE OTHER?
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AAT THSY BIASED? THEY E-..'-....-.'-...'-...-....---nE, CE,RTATNLY CENERATED BY A
LAW ENFORCEMENT OEEICER' YES' I WOULD AGREE WITH THAT.
Q OKAY.
AND SO ESSENTIALLY IN EORMING WHATEVER CONCLUSIONS IT
IS YOU, RE EORMING, YOU'RE HAVING TO ACCEPT WHATEVER HAPPENS TO
BE IN THOSE POLICE REPORTS, WHICH YOU UNDERSTAND' I DON'T HAVE'
RIGHT? YOU UNDERSTAND I HAVEN,T GOTTEN DISCOVERY' SO I DON,T
HAVE THOSE.
I DID NOT UNDERSTAND THAT.
Q OKAY.
BUT __ BUT WHATEVER OPINIONS YOU, RE COMING TO, YOU,RE
RELYING ON WHATEVER'S CONTA]NED IN THOSE REPORTS, HOWEVER
ACCURATE OR INACCURATE THEY MAY BE, OR EXAGGERATED, THAT' S __
THAT'S WHAT YOU'VE GOT ?
o
II-J.
OKAY .
ALL R]GHT, SO THE REPORTS I UNDERSTAND. AND WERE
THERE WITNESS STATEMENTS IN THE __ THAT TWENTY_ONE PAGE REPORT?
I,D HAVE TO LOOK BACK AT IT. I DON'T __ I DON'T KNOW
THAT THEY WERE SPECIE]CALLY STATEMENTS. THERE MAY HAVE BEEN
WITNESS STATEMENTS THAT WERE SUMMARIZED IN SUPPLEMENTAL
PORT]ONS OE THE ]NVESTIGAT]VE SUMMARY.
OKAY.
AND THEN I'VE NOTICtrD IN __ IN TALKINC ABOUT THIS,
IS THAT YOU REV]EWED, YOU DID NOT TELL US THAT YOUWHAT IT
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ACTUALLY REVIEWED ANY OTHER EMAIL COMMUN]CATIONS E'ROM MS. MCCOY
TO A}IYONE ELSE ?
A OTHER THAN WHAT ]S __ h]ITHIN THE INVESTIGATIVE REPORT
AND POI,ICE REPORT THAT I REVIEWED, THERE WERE EMAILS THAT WERE
CUT AND PASTED. ]T WASN'T _- ]T WAS IJOT THE ACTUAL EIIAIL THAT
SORT OF HAD THE HEADER AT THE TOP __
SURE.
A -- BUT IT USED SOME OF THE LANGUAGE A},]D WAS CL]T AND
PASTED WITHIN THE TEXT OE THAT INVESTIGATIVE RF]PORT.
Q OKAY,
ALL R]GHT, SO IN EORMING WIIATEVER OP]II]ONS OR
CONCLUSIONS YOU HAVE, YOU AGREE YOU HAVEN'T EVEN ACTUALLY SEEN
ANY OF THE EPIAILS THAT ARE AT ISSUE IIi THEIR COMPLETE EORM,
RlGHT ?
A NOT II\l THEIR COI'IPLETE EORM| NO.
Q OKAY.
AND IE THESE EMAILS WERE RATHER LENGTHY, OUITE A EEW
PAGES, AND THE -- WHOEVER AUTHORED THE POLICE REPORT PULLED OUT
JUST CERTAIN SENTENCES, OR CERTAIN WORDS, OR CERTAIN
STATEMENTS, YOU WOULD AGREE -- YOU' VE BEEN DOING THIS A LONG
TIME, THAT CAN OBVIOUSLY BE EXTREMELY MISLEADINIG TO -- TO THE
READER OF THE REPORT, ISN'T THAT TRUE? YOU'RE NOT SEEING ALL
OF THE
A YES/ 1T COULD __ IT COULD, YES. 1T COULD SWAY THE
READER TO SEE IT IN ONE WAY INSTEAD OE ANOTHER,
tt tt
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THERE ARE
OKAY.
ALL RIGHT, SO ARE YOU AWARE THAT IN THOSE REPORTS
NO DIRIiCT THREATS OF VIOLENCE?
THAT IS MY UNDERSTAND]NG, THAT ]S CORRECT.
OKAY.
ARE YOU AWARE THAT IN EMA]LS THAT WE'RE TALK]NG ABOUT
EROM THE EALL OF LAST YEAR, THAT MANY OF THESE EMAILS, IF NOT
MOST OF THESE EMAILS, ACTUALLY WERE D]RECTED TO NUMEROUS
INDIVIDUALS, INCLUDING THE D]STR]CT ATTORNEY OF COBB COUNTY,
THE CHIEE ASSISTAIIT DISTRICT ATTCRI{EY, A}"]D A HCST OE OTHER
]NDIV I DUALS ?
A
o
Q
A THAT IS CORRECT, THAT'S MY UNDERSTANDING.
OKAY.
Q ALL R]GHT.
AND WERE YOU AWARE THAT NONE OE THOSE OTHER
IND]VIDUALS EVER CAME UP HI]RE TO __ TO SEEK A I,dARRANT?
A THAT IS MY UNDERSTANDING. THERE WERE A EEW
IND]V] DUALS THAT WERE CONCERNED, BUT NOT EVERYONE THAT WAS ON
THE DISTRIBUTION LI ST.
uA /E )la)T Ar\/TtrI^]trn A\lV
PSYCHIATRIC RECORDS,
SO OBVIOUSLY/ YOU __ YOU HAVE
MET)ICAL RECORDS WHAT-SOEVEB..
FROM I'1S . MCCOY ?
WOULD PROVIDE THEM TO ME, IA NO. IF YOU
NOT __ YOU
ANY
LOOK AT THEM.
OKAY .
HAPPY TO
WOULD BE
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WHAT EVER
YOU, VE NOT REVIEWED ANY IN MAKING I,{HATEVER
CONCLUS]ON YOU HAVE, RI GHT ?
THAT IS CORRECT.
ALL RTGHT.
A
O
SO, WE HAVE NO __ YOU DID NOT SEE THE EMAILS IN THEIR
ENTIRETY, YOU DID NOT SEE MEDICAL RECORDS, AND YOU HAVE NOT
SEEN A1''] Y PSYCH P.ECORDS, RIGHT?
A THAT ISJ CORRECT.
Q YOU, I I'J FACT, KNOW ONLY THAT MS. MCCOY WAS IN
R]DGEV]EW TOR A PERIOD OF ]']ME, CORRECT?
A
o
LOT OE --
ADD]CT ION
CORRECT ?
THAT IS CORRECT.
ALL RIGHT.
AND YOU KI.IOW THAT R]DGEVIEW, I I\] FACT, DEALS b]ITH A
A LOT OE ]SSUES. MENTAL ]LLNESSES, AS WELL AS
ISSUES, THEY __ THEY DEAL WITH A VAF,]TY OE MAT!]ERS,
THAT 1S CORRECT.
AND YOU T,iOULD AGREE THAT }IOT EVERYBODY THAT GOES INTO
RIDGEVIEI/i HAS A MENTA], ILLNESS?
A THAT I WOULD HAVE TO DISAGIIEE. IN ORDER FOR TIIEM TO
BE ADMITTED, THEI WOULD HAVE TO HAVE SOME DiAGNOSIS OF' RECORD
TO OBTAIN TREATMENT THERE.
Q ALL RIGHT.
WELL, LET'S __ LET'S DO THIS. WHAT ABOUT SO}IEUNE WHO
HAS DEPF.ESS]ON, OKAY? !.JHAT IE THEY SHOW UP AND THEY'RE
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DEPRESSED? COULD THEY BE ADMITTED TO RIDGEVIEW EOR DEPRESS ION?
ILLNESS .YES, DEPRESSION IS A MENTAL
WHAT ABOUT AN:{IETY?
YES, AI]X]ETY IS A MEI.iTA], ILLNESS.
WHAT ABOUT A FEELING OE HOPELESSNESS?
IJO, I AM NOT .
OKAY .
A HOPELESSNESS IS A SYMPTOM OE ANOTHER MENTAL ]LLTIESS.
Q YOU TALKED ABOUT _- AND I WANT TO MAKE SURE THAT -_
THAT ONE THING/ S REAL CLEAR. YOU HAVE NOT ACTUALLY -- YOU'RE
NOT DIAGNOSII'IG HER I,{ITH ANYTHING, ARE YOU?
A
O
A
O
DEAL WITH, RIGHT?
THERE WERE SOME PHRASES THAT I,iERE TOSSED AROUND, AND
ONE OE THOSE WAS RETRIBUTION STALKER, OR REVENGE STALKtrR?
THE COURT: RESENTEUL STALKER.
Q (BY MR, K]LGORE) IS THAT RESENTFUL STALKER?
A THE JUDGE HAS IT CORRECT, YES.
Q OKAY.
AND ALL THAT IS, IS THAT _- THAT IS "-UST SIMPLY A
CATEGORY THAT YOU TR]ED TO FlT __ YOU MIGHT TRY TO FIT CERTAIIN
__ CERTAIIJ CASES INTO ?
THAT IS CORF,ECT.
AS A __ AS A i,{AY TO EURTHER DIAGNOSE, AND TREAT / AND
A
0
THAT TS CORP.ECT.
OKAY.
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SAY THAT _- SAY THAT PHRASE AGAIN?
A RESENTEUL.
Q OKAY.
AND I BELIEVE WHAT YOU SA]D WAS A REAL HALLMARK OE
THAT, WAS THE GOAL IS TO CAUSE PAIN.
A THAT IS A __ ]E -- IE THAT PERSON IS ENGAGED IN
RESENTFUL STALKING, THAT 1S CORRECT.
A RIGHT, CAUSE PAIN AND DlSCOMFORT TO SOMEBODY ELSE
THROUGH THE CONTACT.
Q OKAY.
SO IE THAT'S rllHAT 15 GOING ON, THEN THE GOAL WOULD BE
TO CAUSE PAIN.
Q OKAY.
LET ME SEE THE LETTER YOU GOT EROM PAUL CAMARILLO,
PLEASE.
A YES, SIR.
Q ALL RIGHT. OKAY.
AND PAUL CAMARILLO YOU KNOW TO BE A __ AN ASSISTANT
DISTRICT ATTORNI]Y, RI GHT ?
A BqSLD ON THAT __
Q OKAY.
A -- YES.
Q ATT, RTCHT.
AND YOU WOULD ACREE THAT WHAT !.JAS BEING CONVEYED TO
PAUL CAMARI.LLO tsY MS. MCCOY WAS THAT __ WHAT SHE WAS REQUESTING
92
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WAS SHE IdANTED TO SEE IE
BOI]D CO}'IDlTIONS SO THAT
ME SHOW YOU THAT.
A
o
OUR OEFICE COULD
SHE COULD GO BACK
HELP HER CHANGE HER
I I]TO HER HOUSE. LET
A THAT IS CORRECT.
Q SHE WANTED TO SEE
THE BOND CONDITIONS SO SHE
AP PEARS
INTO !IER HOUSE?
BASED
OKAY.
THERE'
IE OUR OFE'ICE COULD HELP HER CHANGE
COULD GO BACK ]NTO HER HOUSE?
ON THIS EMAIL, THAT ]S CORRECT
CORRECT.
av 7\-/
SO AS EAR AS THE DA'S OEFICE'S COMMUNICAT]ON, IT
THAT WHAT HER CONCERN WAS, WAS ACTUALLY GETTING BACK
PART]CULAR EMA]L
TO CAUSE PAIN TO
A NOT IN
OKAY.
S NOTHING II.i THAT PARTICULAR -_ IN THAT
THERE'S NOTHING TO SUGGEST AN INTENT OR DESIRE
ANYBODY, RI GHT ?
THIS EtlAIL/ NO.
AND OE THE MATER]ALS THAT YOU WERE ABLE TO REVIEW,
DID __ DID _. DID YOU SEE A COURT ORDER FROM THIS COURT THAT
WAS A PROTECTIVE ORDER ORDER]NG THAT MS. MCCOY STAY AT LEAST
EIVE HLTNDRED YARDS AWAY TROT1 MR. PARIS?
I DlD INOT SEE THE SPECIFIC ORDEP. FPOI.,I THE COUF.T. ]
SAI,.J REF'EP.E\ICE TO THAT ORDER IN A NUMBER OE THE DOCUMENTS
Q ALL RIGHT.
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A
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AND YOU HAD SOME TELEPHONE COMMUNICATIONS !'JITH
COUNSEL, YOU SAID, RIGHT ?
A WITH MS. JACKSON? YES.
Q ALL RIGHT.
LIKE ANY CASE, THE LAWYER'S GOT TO GET YOU UP TO
SPEED, TELL YOU !^IHAT, S GO]NG ON, RIGHT?
OF TWO
REMOVE D
ALL RIGHT.
SO, DID SHE TELL YOU THAT ON JANUARY THE NINETEENTH,
THOUSAND S]XTEEN, THAT THIS LADY WAS, BY COURT ORDER,
EROM HER HOME ?
A I DON'T RECALL IE THAT WAS STATED OR NOT.
Q WERE YOU AWARE OF THAT?
A 1 WAS AWARE THAT SHE WAS NOT AT HER OWN HOUSE. BASED
ON THIS COMMUNICATION.
Q OKAY.
LIVED IN
MARR]AGE,
WERE YOU AWARE THAT THAT WAS THE HOME THAT SHE HAS
W]TH HER HUSBAND DURING THE ENTIRE TERM OE HER
]NCLUDTNG THE BIRTH AND RAISING ALL OE HER CH]LDREN?
I WAS NOT.
OKAY.
YOU'LL __ WERE YOU AWARE THAT THAT WAS ACTUALLY THE
IlOMtr BELONGING TO IIER ItUSBAND'S PARENTS?
I ViAS NOT.
WF',RF, YOI] AWARE THAT SHE IS THE PR]MARY CAREGIVER
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INSIDE OF THAT HOI.{E TO THE YOUNG CHILDREN
READY I'OR SCHOOL, AND EEED, AND TAKE CARE
A NO, ONLY IN THE CONTEXT OE I,{HAT
MS. JACKSON EROM MR. CAMAR]LLO, THAT SHE
r/.]HO SHE HAS TO GET
OF?
WAS ]N THE EMA]L TO
WANTED TO GET BACK TO
CARING EOR HER CH ILDREN
OKAY, LA/ANTEI) TO GET BACK TO CAR]NG FOR HER -_ CARII"]G
EOR HER CHTLDREN.
AI.ID YOU WOULD AGREE THAT THAT
SENT]IIENT, AT LEAST WHAT YOU HAVE THERE,
GOAL, TO GET BACK II] HER HC]VJE?
EXPRESS I ON,
APPEARED TO BE THE
A A PORT]ON OF THE GOAL. YES. THAT'S CORRECT.
[]ELL. THAT' S WHAT SHE
RELATED TO JUST 'IAK]I'JG CARE OF
IN THE HOME SO THAT SHE CAI,.] BE
WITH HER HUSBAND AND CH]LDREN.
TALKED TO PAUL CAMAR]LLO ABOUT.
BUT I THOUGHT YOUR QUEST]OI.I I,{AS
THE CHILDREN. YES, TT'S TO GE'f
W]TH HER -- AS SHE SIIATED, TO BE
A vtr< .Tu.!rn. e __
ALL RIGHT.
D]D -- ]N -- ]N REV]ET{ING THE MATERIALS, lOU GOT
THE DATII THAT SHE WASSCMETH]NG FROM R]DGEVIEW. DO YOU HAVE
ADMITTED TO RI DGEVIEW?
A I DID NOT.
O I^JELL, ]N SPEAKII,]G TO MS. JACKSON. DID __ DID SIIE TELL
YOU THAT TWO DAYS __ TWO DAYS AFTER SHE WAS RE}4OVED EROM HER
HOME BY COURT ORDER, THAT SHE WENT IIJTO R]DGEVIEW HOSP]TAL?
DGEVI EV,] HOS PITALI I{AS INTORMED THAT SHE, WENT INTO RI
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ICH IS THE DATE HERE ON
THE RIDGEVIE!.i VERIFICATION LETTER, BUT I DO NOT KNOI/i THE
SPECIEIC DATES THAT SHE WENT INTO RIDGEVTEW HOSPITAL'
Q I WANT YOU TO CONSIDER SOMEONE WHO HAS NEVER BEEN
CONVICTED OF A CRIME, WHO IS A MEMBER OE THE STATE BAR OE
GEORGIA. WHO IS A MOTHER, WHO IS RAISING CHILDREN IN HER HOME
W]TH HER HUSBAND, IN A VERY NICE, VERY NICE NEIGHBORHOOD' ANI)
SHE/S ORDERED OUT OE THAT HOME, AND SHE,S EORCED TO LEAVE THAT
HOMEIANDESSENTIALLYBECOMEHOMELESS,FLNDSOMEOTHERPLACETo
LIVE, AND I WANT YOU TO CONSIDER THAT SHE CAN, T BE THERE IN THE
MORNING TO GET HER KIDS UP. TO HELP GET THEM DRESSED, TO GET
THEM EED, GET THE]B LUNCHES READYT GET THEM TO SCHOOL, SHE
CAN'T BE THERE IN HER HOME TO __ TO SEE THEM OEE THE BUS, OR TO
PICK THEM UP AT SCHOOL AND TAKE THEM HOME TO CARE TOR THEM, TO
GET THEM READY EOR THE]R BALL GAMES, I WANT YOU TO CONSIDER
THTS SAME INDIVIDUAL CAN'T DO ANY OE THAT, I WANT YOU TO
CONSIDER THAT TH]S INDIVIDUAL IS HUM]LIATED PUBL]CLY BY A
HEAR]NG WHERE]N SHE WAS ACCUSED OE THREATENING POLITICALLY
CONNI]C'.t L]D -LN D1V l DUA-LS. OKAY?
NOW, WHAT THAT INFORMATION, WOULD YOU AGREE THAT THAT
CERTA]NLY IS A REC]PE FOR A WOMAN IN THAT POSIT]ON TO BE
DEPRESSED?
A ]T IS IT IS -- I WOULD AGRtrtr THAT IS A VtrT]Y
STRESSFUL SITUATlON FOR ANYONE. MALE OR FEMALE.
O THAT'S THE __ THAT'S THE KIND OE SITUATION THAT WILL
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causr aNxrETY, ISN'T IT?
A IT ]S.
O OKAY.
AND DON'T YOU AGREE THAT THAT, S EXACTLY THE KIND OE
SITUATION THAT MIGHT LEAD SOMEONE TO HAVE TO SEEK TREATMENT AT
APLACELIKERIDGEVIEI/i,THATTREATSDEPRESS]ONANDANXIETY?
A YES.
O SO LET'S SEE WHAT ELSE WE LOOKED AT. TODAY YOU
RECEIVED SOME EMAIL DOCUMENTS, OKAY. AND YOU HAD TO __ IS
TODAY THE FIRST TIME YOU'VE HAD A CHANCE TO TAKE A LOOK AT
THESE?
A YES, ]T ]S.
Q OKAY.
Q OKAY.
A TIJA_ TS CODDFCT.
AND WERE YOU LED TO BELIEVE THAT THESE EMA]LS WERE
SENT TO ANY INDIVIDUAL WHO SHE HAD PREVTOUSLY BEEN ORDERED NOT
CONTACT ?
A I THINK. IE ] RECALL THE TESTIMONY AND THE QUESTIONS,
IT HAD TO DO WITH. ]S TH]S SOMEONE NEXT TO, OR CLOSE TO, A
ERIEND OF PERHAPS ONE OF THOSE PEOPLE THAT SHE WAS TOLD NOT TO
HAVE CONTACT WITH.
WEiL, YOU WOULD AGREE IN ALL OE THESE COMMUNICATlONS,
NOWHERE IN HERE AT ALL, IS THERE ANY SUGGESTION TF1AT THtr
RECiPItrNT OE THIS EMAIL CONTACT ANYONE ELSE ON HER BEHALF?
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HO!^JEVER, THE -- THE _- THE EMAILS DO MENTION GETTING
BACK ]}.JTO HER _- HER HOME?
A THEY DO.
Q OKAY.
-TUST LIKE I,ITHEN SI]E TALKED ABOUT WITH PAUL CAMARILLO,
THE ASSISTANT DTSTRICT ATTORNEY, R]GHT?
A THAT ]S CORRECT.
Q THE VERY SITUATION THAT COINCIDED I,{ITH]N TWO DAYS OF
HER BEING REMOVED FROM HER HOME, THAT SIIE'S I}J -_ IN __ HAS TO
BE PUT IN F.IDGEVIEW, RIGHT, REMOVAL EROM HER HOME?
Q OKAY.
A THAT'S BASED ON !,iHAT YOU'RE TELLING I,IE / YES, ]E
THAT/ S HOW __ YES.
Q OKAY.
A YES.
Q ALL R]GHT, WOULD YOU AGREE THEN, THAT WHAT WE'RE
TALK]NG ABOUT HERE, THAT -_ AND I'M GOING TO GO STRAIGHT FROM
-_ STRAIGHT EROM THE STATE'S PETITION. OKAY? THE CONTACT WiTH
PAUL CAMAF.ILLO, AND THESE COMMUNICATIONS, YOU !'JOULD AGREE
THERE'S A COMMOI] THEME HERE BETWEEN THOSE, AND THAT 1S, SHE'S
CONCERNED ABOUT GETTING BACK IN HER HOME?
A I AGREE.
Q THERE IS, IIOWEVER, NO SUGGESTION IN EITHER THE
COMMU}JICATION WITH PAUL CAMARILLO, OR THOSE COMMUNICATIONS'
THATSHEIS-_IJASAI{INTENTTOCAI]SEPAINTOSOMEBODY'EVLN
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O
A
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A
ALL RIGHT.
THE COMMI SS IONER OE COBB COUNTY.
ALL RIGHT.
AT MEETINGS, SUCH AS
COMMISSIONER WOULD BE
MEET]NG, Rl GHT ?
WOULD BE A PERSON I,"JHO WOULD, YOU KNOW. BE
THEY'RE TALKING ABOUT HERE. OBVlOUSLY THE
AT THE COBB COUNTY COMMISS]ONER'S
1 WOULD HOPE SO. YES.
OKAY.
AND YOU WOULD AGREE IN TIOWHERE IN THOSE
COMMLIN ICAT IONS , THOSE EMAILS, IS THE _- THE AUTHOR OE THOSE
EMA]LS REQUESTING THAT THE RECIPIEI'.]T, THAT BEING THE
COMMISSIONER, MAKE ANY PHONE CALL ON HER BEHALE?
Q AND THE EMA]L THAT YOU GOT EROI.,I PAUL CAMARILLO IS THE
SAME THING; I MEAN, SHE _- SHE WASN, T DIRECTING HIM TO REACH
OLTT AND COIiTACT ANYBODY ON HER BEHALE, !.1AS SHE?
A
O
A
OKAY .
NO.
SEND ANY EMAIL ON HER BEHALT?
NO.
AND AGAIN, THE __ THE TERM THAT WE WERE USING OI] YOUR
DIRECT, THE TERM RESENTFUL -_ P'ESEI\TTEUL STALKER, AGAIN/ THAT ]S
-- THAT IS JUST A CATEGORY. YOU/F.E NOT -_ YOU' Rtr }JOT MAKING
SOME SORT OF D]AGNOSlS, RIGHT?
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A T]IAT IS CORPECT.
O AIT PTr:HT
MR. KILGORE: JUDGE, I WILL TELL YOU THAT DOCTOR
NORMAN AND I HAVE WORKED TOGETHER MANY TIMES, AND THAT MAY
ACTUALLY HAVE SHORTENED THIS UP QUITE A BIT.
THE COURT: OKAY, RtrDIRECT? A}.IY REDIR,ECT?
MS. JACKSON: YES.
REDIRECT EXAMINAT ION
BY MS. JACKSON:
Q BASED ON YOUR REVIEW OE THE DOCUMENTS AND THE EACTS
THAT HE TOLD YOU, WOULD YOU RECOMMEND ANY HOSPITALIZATION EOR
THIS PERSON ?
A ] DON'T KNOVi THAT __ I MEAN, I -_ I _- I HAVEN'T SEEN
MS. MCCOY. I WOULD !.ECOMMEND THAT __ THAT SOMEONE WHO HAS A _-
HAS COMPETENT EORENSIC TRAINING, DO AN EVAI,UATION, AND TI.{AT
THAT BE PROVIDED TO SOME OTHER OUTSIDE PARTY SO THAT SOMEONE
CAI] ASSESS THAT RI SK AND IIAKE THAT RECOMME}I DAT I OI{ .
]F SOMEBODY HAS A MENTAL ILLNESS. THEY SHOULD BE
RECEIVING MENTA]- HEA].TH 'lREATMENT. AS A PSYCHIATR]ST i WHOLE
HEARTEDLY AGREE h]]TH THAT.
Q AND II'] ORDER TO ATTEND P.JDGEVIE!^i, I{OULDN'T YOU HAVE
TO BE __ HAVE SOME SERIOUS I"IENTAL ILLNESS? FOR EXAMPLE, YOU _-
WOL]LDN'T YOI] BE BtrYOND THEF.APY AND MED]CATION AT HOME?
A THE -- THE _- THAT IS -- THAT IS CORRECT I}] THAT THE
LEVEL OF HOSPITALIZAT]OI'J IS RESERVED FOR A SEVERITY OF ILL\]ESS
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THAT REQUIRES HOSPITAL]ZATION, S]MILAR TO A MEDICAL ILLNESS.
YOU DOIJ'T GET _- YOU CAI.J HAVE WHAT THEY CALT WALKING PITEUMOI{IA.
YOU CAN HAVE PNEUMONIA/ YET NOT BE IN THE HOSP]TAL. YOU CAN
HAVE DEPRESS]ON, YET NOT BE IN THE HOSP]TAL. IE iT __ ]E
SOP]EONE IS IN THE HOSPITAL, ]T ]S OF THE SEVERITY THAT USUALLY
REQU]RES HOSP]TALIZATION.
Q AND IN TALK]NG _- SPEAKING OF THE _- YOU TALKED ABOUT
__ YOU WERE TALKING ABOUT THE REVENGE]FUL STALKEP., WHEN YOU HAVE
SOMEONE WHO ]S ENGAGING IN TH]S TYPE OF BEHAVIOR, AND YOU
TALKED ABOUT THEI'4 I^IANTING TO COMMIT PAIN AND DISCOMEOF,T,
COULDN'T THAT PA]I'J AND D]SCOMFORT INCLUDE MAKING SOMEONE EEEL
UNCOMEORTABLEI OR MAKING SOMEONE FEEI' E'EARFUL THAT THEY'RE
GOING TO BE CONTACTED?
THE TYPICAL BEHAV]OR DOES I.]OT USUALLY RISE TO __ TO VIOLENCE,
BUT ]T CAN. TT TS TO JUST TO CAUSE DISCOMFORT FOR THEM OI'I AN
ONGOING BAS]S. AS LONG AS THEY HAVE DISCOMEORT __ THE
TRADIT]ON IS, THEY HAVE DISCOMEORT ]I.I THETR MIIID OVER THE
S]TUA],ION; WELL, I,M GO]NG TO GIVE IT TO SOMEBODY ELSE.
A ABSOLUTELY. THAT'S USUALLY THE TYPICAL BEHAVIOR.
AND SO THAT ]NCLUDES SENDII{G MESSAGES, YOU KNOW, IN
UllUSIJAI,. OUTSIDE OE BUSINESS HOURS, SE}JDTNG OUT TEXT }IESSAGES
AT SIX O'CLOCK IN THE MORN]NG, OR LETTING SOMEONE KNOh] THAT
YOL]'P.E ALWAYS COING TO Btr THERE, THAT YOU' RE COINC TO PE
CONTACTII.]G THEI'I, THAT YOU'RE GO]NG TO BE SEEING THEM ViHEN YOLI
KNOW THAT THEY DON'T WANT TO HAVE ANY CONTACT WITH YOU?
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A YES.
Q Al'l D !'JHEN YOU LOOKED AT THOSE TEXT MESSAGES, r.^lAS IT
CLEAR TO YOU THAT THE DEEEIJDANT WOULD BE W]LLII.]G TO ENGAGE IN
CERTAIN BEHAVIORS iF SHE DID}J'T GET WHAT SHE WANTED?
A YES, IN THAT THERE WAS A STATEMENT THAT IE I DON,T
GET X, I'M GOING TO CONT]NUE TO SHOW UP TO THE MEETINGS/ AND
THAT _- FROM THAT STANDPOII']T, IT'S I'M GOING TO GO TO THE
I'{EETINGS UNTIL ]'M BACK IN I'{Y HOME.
Q AND WOULD THAT BE __ COULD THAT BE CONS]DERED ONE OE
THOSE ACTS WHERE THE MEANS OT CAUSING DISCOMFORT TO __ TO THE
F.ECIPIE}JT CF THOSE TE}:T MESSAGES?
A IT COULD. AT THE END OF THE DAY. THE THEOF,Y ON THE
STALKER IS THAT THIS ]S AN OBSESSION. THIS IS SOMETH]I.IG THAT'S
STUCK ]N THEIR HEAD, AND IT LOOPS OVER AND OVER AGAII,I . THEY
HAVE A HARD TIME ABOUT THINKING ABOUT ANYTHING ELSE, UNT]L
E]THER, A, THE OBSESSION GOES AWAY, OR THEY FEEL THEY HAVE
CAUSED ENOUGH PAIN T'O STOP IT THEMSELVES.
A\]D YOU TEST]E]ED ABOUT THE CONTACT THAT THE
DEFENDANT MADE WITH CHAIRMAN LEE. ISN'T IT ALSO POSSIBLE THAT
THE DEFE}JDANT COULD HAVE DONE THAT AS A WAY OE GETT]NG TO
SOMEBODY THAT WAS I}I M]CHAEL PARIS/ CIRCLE SO THAT THE __ THE
EACT THAT SHE -_ HE WAS COI\]TACTED WOULD BE RELAYED TO M]CHAEL
PARISI IS TIIAT A COI-I}ION STI].ATEGY
MR. KILGORE: JUDGE, I DON,T -- I DOIVT EVEN
UNDEF.STAND __
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MS. JACKSON:
ART EULLY .
] COULD PROBABLY ASK THAT QUESTIOI] MORE
THE COURT: OKAY, GO AHEAD AND RE_ASK IT, PLEASF].
Q (BY MS, JACKSON) IS IT _- IS IT __ BASED ON YOUR
REVIEI,.I OF THE TEXT MESSAGES AND THE FACTS, !,iOULD IT BE A COMMO},I
STRATEGY OF THE REVENGE TYPE STALKER TO CO|ITACT SOIIEOIJE I l:,J THE
TARGET' S CTRCLE AS A I'IEANS OE GETTING BACK -_
MR. KILGORE: HOLD ON, I'M GOING TO OBJECT TO THAT.
I'M GOING TO OBJECT TO THAT. HlS TESTIMONY WAS THAT HE
HAD I\TOT DIAGNOSED HER AS A RESEI'JTEUL STALKER. THAT WAS
HIS TESTIMONY. SO .- SO AI{Y OTHER OPINTON DOWN THAT __
DOWN THAT ROAD IS COMPLETELY IRRELEVANT. I'M GOING TO
OBJECT TO THAT.
l''1S. JACKSON: LET ME REPHRASE THE QUESTION.
THE COURT: YOU CAN GO AHEAD AND REPHRASE oNE MORE
TIME.
Q (BY I"1S. JACKSON) GIVF]II THAT -- OI{E MORE TII.1E, TAKE
THREE.
GIVEN THAT THE _- WHEN YOU TALKED ABOUT THE DEFENDANT
EI.IGAGI\IG IN BEHAV]OR THAT IS CoI\]S]STENT WITH BEHAVIoP. THAT
TOULD BE SII{ILAR TO A REVE},IGEFUL TYPE STALKER, I.5 I? ONE OE
THOSE BEHAVIORS COMMONLY TO WHEN THEY CAN'T REACH THE
PARTICULAR TARGET THAT THEY' RE OBSESS]NG W]TH, TO TRY TO REACH
SOI.,IEONE THAT'S VERY CLOSE TO THEM AS PART OE THE]R CIRCIE'?
YES.
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Q AND TRY TO USE THEM AS AN OBJECT TO GET BACK AT THE
ORIGINAL TARGET ?
MS. JACKSON
THE COURT:
NOTH]NG EURTHER.
ALL RIGHT, SIR, YOU CAN STEP DOWN, THANK
MAY I BE EXCUSED, YOUR HONOR?
CAN HE BE EREE TO GO? IS HE EREE TO GO?
I HAVE NO EURTHER QUESTIONS.
YES, SIR. HAVE A NICE EVENING.
THANK YOU.
WHO' S YOUR NEXT WITNESS.
YOU.
THE WI TNES S
THE COURT:
MS. JACKSON
THE COURT:
THE WITNESS
THE COURT:
MS. JACKSON: NO FURTHER WITNESSES EOR THE STATE.
THE COURT: MR. KILGORE, WHO.S YOUR EIRST WITNESS?
MR. K]LGORE: WE,RE NOT GOING TO CALL ANYBODY, JUDGE.
THE COURT: ALL RIGHT, SO ] DON, T BELIEVE THERE, S ANY
NEED FOR ANY REBUTTAL h]ITNESSES.
CLOSING ARGUMENTS. IT,S THE STATE, S MOTION; YOU CAN
OPEN, IE YOU WANT.
MS. JACKSON: I' LL CLOSE.
THE COURT: OKAY.
MR. KILGORE.
MR. KILGORtr: THANK YOU, JUDGtr.
(WHEREUPON, ARGUMENT !{AS PRESENTED BY MR. K]LGORE TO
THE COURT ON BEHALF OF THE DEEENDANT. )
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MS . JACKSON: THANK YOU, YOUR HOt'loR.
(WHEREUPON, ARGUMENT WAS PRESENTED BY MS. JACKSON TO
THE COURT ON BEHAI,E OI- THE STATE. )
THE COUF,T; WELL, I,M GO]NG TO PICK UP !.JHERE I LEFT
OFE i,^JHEN I ACTUALLY GRANTED MS . MCCOY A BOND. AND I
RIICALL SITTING HERE. BUT I GAVE HER SOME ADMON I SHMEI'IT S,
AND I WENT A},JD GOT A COPY OE THE TRANSCRIPT SO I COULD
REVIEW THE LANGUAGE THAT I STATE]D AT THE END OF THAT
HEARING WHEF.E SHE GOT A BOND.
A COUPLE THINGS THAT I TOLD HER; ONE !^iAS. THE
PROBLEMS WE LAWYERS _- WE HAVE AS LAWYERS, IS THAT THEFE'S
NO LANGUAGE CLEAR ENOUGH. SPEC]TIC ENOLTGH, DETATLED
ENOUGH, THAT T,4]ILL COVER EVERY INCIDENT.
] WEI]T __ I WEIiT ON TO TELL HER THAT I/M NOT INTO
SPLITT]NG HAIRS, I'M NOT GOING TO DO ANY ROUNDABOUT, THIRD
THE COURT: MS. JACKSON.
PARTY CONTACT. I DON'T SEE ANY LOOPHOLES IN THIS, WASN'T
T ADI',IONISHED HEP. TO TALK TO HEP. LAWYEF.S BEEORE DOINC
:NTO SHOWMANSHIP, GRAN DSTANDI I.]G, DlDN'T EXPECT ANY, WASN'T
GOING '1'O TLTLERATE ANY, WASN'T GOING TO DANCE THIS CASE ON
THE HEAD OF A PIN.
I ALSO TOLD HER THAT IF THERE'S A HINT OF ANY
VlOLAT]ON, SHE COULD GO BACK INTO CUSTODY.
A}]YTHING, AND I WASN'T COING TO SPLIT HAIRS, THAT SHE
NEEDED TO AB]DE BY THE SPIRIT OF THE COND]T]ONS, AND WHEN
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]N DOUBT. TALK TO YOUR LAWYERS BEFORE MAKING ANY
DECISTONS, AND SHE ACKNObILEDGED THAT WITH A YES, SIR.
AND HERE ] AM FINDING MYSELE DANCING THIS CASE ON THE
HEAD OE A PIN. SPLITTING HAIRS LOOK]NG EOR LOOPHOLES, AND
I,14 NOT GOl},]G TO TOLEP.ATE ]T.
I E]ND THERE'S NO REASON FOR HER TO HAVE TEXTED MR.
LEE, PART]CULARLY hIITH THE INEORMATION ABOUT GETTII,]G BACK
IIITO HER HOME. IE THAT WAS OMITTED, I DON'T THINK WE'D BE
HIIRE TODAY. BUT THAT IN AND OE' ITSELF IS OE' CONCERN TO ME.
PRETR]AL SERVICES DOESN'T HAVE THE MEDICATIOI..I
EVALUATION. APPARENTLY BY HER OI,,]N REPORT THE DA' S OEEICE
THAT SHE SHOI"JS UP TO. W]THOUT HF]R LAWYERS PRESENT, THAT
SI]E'S NOT COI4PLYING -. OP. DOESN'T __ ISN'T O}J ANY
MEDICATION, SO THE LOI]G AND THE SHORT OE IT IS, I'M GOING
TO REVOKE HER BOND.
IE YOU'RE GOING TO F]LE EOR A BOND CO},]SIDERATION IN
THE EUTURE, I WILL TELL YOU THAT I NEED SOME SUBSTAI.JTIAL
I4EDICAL IIJEORMATIOI.i ABOL]T WHAT'S GOING OI{ b]ITH HER AND HEP.
CASE BEFORE I'LL CONS] DER A BOND.
THAT'S MY DECISION.
(CONCLUSION OE BOND REVOCATION HEARII\lG. )
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CERTIFICATE
GEORGIA
COBB COUNTY
I HEREBY CERTIFY THAT THE FOLLOWING HEARING WAS TAKEN DOWN
AS STATED IN THE CAPT]ON, AND THE QUESTIONS AND THE ANSWERS
THERETO WERE REDUCED TO TYPEWRITING UNDER MY DIRECT]ON; THAT
// '7THE FOREGOING PAGES 3 THROUGH /'( / REPRESENT A TRUE AND
CORRECT TRANSCRfPT OF THE EVIDENCE GIVEN BY SAID WITNESSES UPON
SAID HEARING; AND I EURTHER CERTIEY THAT I AM NOT KIN OR
COUNSEL TO THE PARTIES IN THE CASE, AM NOT IN THE REGULAR
EMPLOY OF COUNSEL EOR ANY OE SAID PARTIES; NOR AM I IN ANYWISE
INTERESTED IN THE RESULT OE SAID CASE.
!./ 1/'/THF / I,THIS, DAY OF , 2016.
'. r I I
ROBERT G. HALVORSON
CERT]F]ED COURT REPORTER
(B-407 )